Section 148 Notice Invalid: No Failure to Disclose in Original Assessment, Invalidates Reassessment u/s 147.

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....Reassessment u/s 147 - original assessment u/s 143(3) - notice u/s 148 after expiry of four years - A bare perusal of the recorded reasons shows that there is no whisper in the reasons recorded that there was failure on the part of the assessee to disclose fully and truly all material facts necessary for his assessment - issuance of notice u/s 148(2) as well as order passed u/s147 is bad in law....