Reopening Tax Assessment Valid Beyond Four Years if Section 147 Requirements Met; Challenges in Writ Not Allowed.

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....Reopening of assessment u/s 147 - Reassessment beyond the period of four years - sufficiency of the reasons cannot be gone into in a writ proceedings - Perusal of the above findings of the 3rd respondent would be sufficient to hold that the requirements of Section 147 of the Act has been complied with and the initiation of reopening proceedings is well within the provisions of the Act and therefore, the respondents are at liberty to proceed with re-assessment by following the procedures - HC....