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2023 (3) TMI 154 - GUJARAT HIGH COURTReopening of assessment u/s 147 - validity of notice u/s 148A - serious allegations of breach of principle of natural justice and issuance of notice u/s 148 - HELD THAT:- Since the order has been disposed off in complete disregard to the details which have been furnished, in our opinion, it is in breach of principles of natural justice and the matter shall need to be sent back to the officer concerned from the stage where he has committed serious error in not complying with the statutory requirements. The least that could have been done is to follow the principles of natural justice and also adhere to the provisions prescribed under the statute. We appreciate the fairness on the part of the learned counsel for the other side. The order u/s 148A(d) as well as notice u/s 148A of the I.T. Act need to be quashed.
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