The notice of analysis does not have to specify whether it is under section 147 (a) or 147 (b), there is no need to present the reasons for re-evaluation in the notice which is recorded. Failure to disclose material facts that have escaped the assessment of income is the amount shown in the profits but claimed to be exempt because the claim for capital receipts was accepted at the time of actual assessment of receipts. Review proceedings for assessment are not valid under section 147 (a) or section 147 (b) of the Indian Income Tax Act, 1961, section 147. Same.
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