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2003 (12) TMI 31 - BOMBAY HIGH COURT
Notice u/s 148 to reopen the assessment – limitation - reason for reopening of the assessment is the net profit at 17 per cent, of the total costs adopted by the Assessing Officer for the assessment year 2000-01 - Nowhere in the reasons recorded by the Assessing Officer, is it stated that there is a failure on the part of the assessee to disclose material facts in the return filed - In the absence of any failure on the part of the assessee to disclose fully and truly all material facts, the reopening of the assessment beyond the period of four years is not sustainable