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<h1>Successful Petition Challenges Assessment Notice Timing, Emphasizes Right to Notice and Hearing</h1> The petition challenging assessment proceedings due to a notice issued beyond the limitation period was successful. The court emphasized the importance of ... - The petition challenged the initiation of assessment proceedings due to a pre-assessment notice issued beyond the limitation period. The court held that the Commissioner's power to defer assessment cannot be exercised arbitrarily and must be for valid reasons. As no notice was given to the petitioner before deferring the assessment, the proceedings were quashed. The petitioner's right to be heard before altering their position was emphasized. The petition was allowed, and the rule made absolute.
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