Landmark decision by Supreme Court during Lock down period in the case of NDTV on 3rd April 2020. Appeal allow by holding that the notice u/s 148 is valid when the revenue discovered fresh tangible material. However no addition can be made when the assessee had fully and truly disclosed all material facts during assessment proceedings 143(3). The assessee must be put to notice of all the provisions on which the revenue relies upon. If the notice does not mention of second proviso of section 147 the court will not allow to treat as a notice invoking provisions of the second proviso of Section 147 of the Act.
