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2011 (10) TMI 11 - BOMBAY HIGH COURTReason to believe - The challenge in these proceedings under Article 226 of the Constitution is to the action of the Assessing Officer in reopening the assessments for Assessment Years 2005-06 and 2006-07 on the basis of certain documents impounded on survey u/s 133A. - Held that:- When the reopening takes place within a period of four years of the relevant Assessment Year, the powers of the Assessing Officer are substantially wider than when a reopening is beyond a period of four years. - The record impounded in survey constitute tangible material for reopening the assessment for Assessment Years 2005-06 and 2006-07. Decided against Assessee
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