On basis of information that the assessee had made payments to some companies which were not genuinely engaged in business of sale of software, it was concluded that purchase made by assessee-company had to be disallowed and considered for tax incidence and, thus, reassessment was initiated. On writ dismissing the petition the Court held that since disputed facts could not be gone into by High Court in a writ proceeding under article 226, which was to be done with reference to documents as well as evidences made available before competent authority and reasons furnished for reopening of assessment as well as findings made in order disposing of objections were candid and convincing, reopening of assessment was justified.  (AY. 2010-11)