Sec. 147, 148 of the Income-tax Act, 1961 — Income escaping assessment - High Court while quashing the impugned notice issued to the petitioner-assessee under section 148 of the Act, 1961 held that “Undisputedly, there is no new tangible material received by the AO that has triggered the impugned notice. Moreover, these reasons, further, record that the interest on fixed deposit amounting to Rs. 1.84 crore have been credited to profit and loss account and have been offered to tax by the petitioner as part of its business income, however, the same was not accepted by the AO on the ground that the petitioner did not carry out any business. Be that as it may, the impugned notice is clearly hit by the first proviso to Section 147 of the Act as there has been no failure on the part of the petitioner to disclose truly and fully all material facts necessary for assessment in the proceedings leading to an order under Section 143(3) of the Act. SLP of the revenue dismissed on account of low tax effect. - DY. CIT V/s KUNDAN CARE PRODUCTS LTD. - [2020] 269 TAXMAN 012 (SC)