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2022 (6) TMI 1301 - CALCUTTA HIGH COURTReopening of assessment u/s 147 - notice u/s 148A(b) - No discussion on objection case of the petitioner that the impugned order is bad in law - HELD THAT:- On perusal of the aforesaid order u/s 148A(d) no reasoning or any discussion on the contention raised by the petitioner in its aforesaid objection. Advocate appearing for the respondent could not justify the aforesaid impugned order by his submission. Considering the submission of the parties, the aforesaid impugned order u/s 148A(d) and subsequent notice under Section 148 are set aside and the matter is remanded back to the AO concerned for passing a fresh order in accordance with law and by passing a reasoned and speaking order particularly by taking into consideration the objection of the petitioner within eight weeks from the date of the communication of this order. Before passing any fresh order u/s 148A(d) petitioner or its authorised representative shall be given opportunity of hearing.
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