gujarat high court in case of hotel oasis in s.c.a. 10657/09 has considered aspect of factually incorrect premises as incorrect basis for reopning.
reopening is not sustainable on same issue for which revision proceedings are at appellate level .
reopening is not for making inquiries to be done in regular assessment.
significant aspect is at para. 23. objection disposal is not an empty formality and reasons are to be given for rejection of assessee's contentions.
r.k.patel