Section 147 of the Income Tax Act, 1961 – Reassessment – Merely alleging that there is failure to disclose truly and fully all material facts necessary for assessment would not satisfy the jurisdictional requirement unless the reasons indicate what material facts the assessee had failed to disclose fully and truly during the course of the regular assessment. Basis of the reason to believe was a subject matter of consideration by the AO while passing the assessment order under section 143(3), hence the reason to support would be a clear case of change of opinion and reopening notice would be without jurisdiction – SS Landmarks vs. Income tax Officer [2020] 312 CTR (Bombay) 402