In the result, both the appeals are dismissed
Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria
TDS can not held to be non disclosure of the full particulars. In view of the aforesaid facts and circumstances, we find that the notice under Section 147 of the Act to the petitioner stands vitiated in non compliance or fulfilment of the second condition as laid down in the proviso to Section 147 of the Act.” Shri Anil Kumar