Where assessee had obtained approval for establishing an industrial park and subsequently number of industrial units was reduced from 14 to 6 due to merger/amalgamation by unit holders, and Central Government issued notification retrospectively revoking approval on ground that condition of maintaining minimum 14 units was not complied with, assessee failed to demonstrate by clear pleadings or arguments that notification was ultra vires; documents also indicated non-compliance with the approval condition and there was no non-compliance with jurisdictional parameters in reopening proceedings; accordingly, impugned notification revoking approval and reopening notice could not be interfered with.. (AY. 2007-08 to 2011-12)