Section 8(a) in The Companies (Profits) Surtax Act, 1964
(a)the [Assessing Officer] [Substituted for the words "Income-tax Officer" by Act 04 of 1988, section 187] has reason to believe that by reason of the omission or failure on the part of the assessee to make a return under section 5 for any assessment year or to disclose fully and truly all material facts necessary for this assessment for any assessment year, chargeable profits for that year have escaped assessment or have been under-assessed or assessee at too low a rate or have been made the subject of excessive relief under this Act, or
