Re-assessment proceedings based on mere bald statement that assessee has failed to make a full & true disclosure of material facts not sufficient

Bald statement that assessee has failed to make a full & true disclosure of material facts not sufficient. Details must be given as to which fact was not disclosed It is true that the reasons for initiating re-assessment proceedings do  in fact state that there was a failure on the part of the Petitioner to disclose fully and truly all material facts necessary for its assessment. However, as correctly submitted by Mr Dastoor, merely making this bald assertion was not enough. In this regard, the reliance placed by Mr. Dastoor on a Division Bench judgment of this Court in the case of Hindus...