(1.) RULE, returnable forthwith. By consent of parties, Rule is taken up for final hearing.
(2.) IN this petition, the petitioners are challenging the notice dated 5th november, 2002/or reopening the assessment for assessment year 1996-97, issued by respondent No. 1, under section 148 of the Income Tax Act, 1961 ("act" for the short ).
(3.) THE petitioners are engaged in the business of manufacture of various consumer products in respect of which excise duty is payable. The petitioners also import certain raw materials for its manufacturing activities subject to payment of customs duty may be leviable under the provisions of the Customs Act, 1962.