In absence of failure to disclose fully & truly all material facts- reassessment notice invalid

Usha Exports Vs ACIT (Bombay High Court) The first contention raised by Dr. Shivram regarding the absence of statement regarding petitioner’s failure in the reasons is correct. The reasons supplied along with the impugned notice, which are reproduced above, contain no assertion there was any failure of the petitioner to disclose fully and truly all material facts necessary for the assessment. This omission can be a ground to set aside the Reassessment notice. Pursuant to the reasons given along with first reopening notice dated 29 September 2012, the Petitioner had supplied all the mater...