Notice for Reopening Assessment Must State Assessee's Failure to Disclose Facts u/s 147.

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....Reopening of assessment u/s 147 - the notice must stipulate that there was a failure on the part of the assessee to disclose fully and truly material facts necessary for its assessment and discovery of such new material, details of which are required to set out in the notice could be the only material to form the basis for assuming jurisdiction u/s 147 - HC....