The Assessing Officer has to give details in the recorded reasons as to which fact or material was not disclosed by the Petitioner that led to its income escaping assessment. A mere bald assertion in the reasons that there was a failure on the part of the Petitioner to disclose fully and truly all material facts, without giving any details thereto is not sufficient. This being the case, the impugned Notice is bad in law on this ground alone and the Petitioner would be entitled to succeed in this Writ Petition.

(a) Ananta Landmark (P) Ltd. Vs. DCIT [2021] 439 ITR 168 (Bombay)
(b) Hindustan Lever Ltd. Vs. R.B. Wadkar [2004] 268 ITR 332 (Bombay)
(c) Lupin Ltd. Vs. ACIT [2014] 46 taxmann.com 396 (Bombay)
(d) Idea Cellular Ltd. Vs. DCIT [2008] 301 ITR 407 (Bombay)
(e) First Source Solutions Ltd. Vs. ACIT [2021] 438 ITR 139 (Bombay)
(f) Saraswat Co-operative Bank Ltd. Vs. ACIT [2024] 166 taxmann.com 360 (Bombay)
(g) Bombay Stock Exchange Ltd. Vs. Deputy Director of Income tax (Exemption) and Ors. [2014] 365 ITR 181.