Section 147 & 148  of the Income Tax Act, 1961 — Reassessment — When the Assessing Officer had not even alleged the failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment, then the reopening after four years was not sustainable as it was hit by the proviso to section 147— There could not be two approvals of the same reasons by the AO for issuing the notice under section 148 — Tarun Goel vs. Income Tax Officer [2020] 77 ITR (trib) 133 (Jaipur)