On an appeal against the order of single judge, the division bench held that where reassessment proceedings were initiated solely on the basis of an inadvertent error in Form 10CCB, in which the chartered accountant mentioned the date of grant of licence to work as the date of commencement of commercial production, the High Court held that such an error could not justify reopening of assessment. The date of licence can never normally be the date of commencement of business, and the mismatch in Form 10CCB itself showed that the mistake was bona fide and not motivated by any intention to suppress material facts. Since there was no failure on the part of the assessee to make a true and full disclosure, the Department was not entitled to invoke the extended limitation of six years under the proviso to S. 147. Further, reassessment was finalized without issuance of mandatory notice u/s 143(2), violating principles of natural justice. Accordingly, the reassessment notice and the order rejecting objections were quashed.  Writ appeals are dismissed.  (AY. 2002-03 to 2004-05)