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2014 (9) TMI 46 - BOMBAY HIGH COURTExercise of jurisdiction under Article 226 - Reopening of assessment u/s 148 – Rejection of assessee’s objection – Held that:- The assessment sought to be reopened was for a period of more than 4 years from the end of the relevant assessment year - Therefore a higher degree of satisfaction is required in cases where the assessment sought to be reopened is beyond four years - during the original assessment proceedings the AO had proceeded on the basis that the purchase details furnished by the petitioners including the bills of purchase are genuine - The information obtained subsequent to the assessment indicate that certain purchase details may not be genuine - the occasion to consider the genuineness of the purchase bill was never a subject matter of scrutiny in the proceedings u/s 143(3) of the Act for A.Y. 2006-07 and 2007-08 – the notice issued for reassessment u/s 148 cannot be interfered – Decided against Assessee.
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