Special leave petition dismissed; assessee must be provided material and reasons for reopening assessment; legal issues left open

SC dismissed the special leave petition and upheld the HC order directing that the material relied on and the reasons to believe for reopening an assessment must be supplied to the assessee. The SC found no basis to interfere with the HC decision. The petition is dismissed, but all questions of law, including the issue of limitation, are left open for consideration by the appropriate authority.

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The Supreme Court declined to disturb the High Court's order, holding there was "no good ground to interfere with the impugned order passed by the High Court." The Special Leave Petition was dismissed: "The Special Leave Petition is, accordingly, dismissed." The Court expressly preserved appellate and substantive challenges by stating that "all questions of law are kept open to be canvassed before the authority concerned including the issue of limitation." Pending applications were disposed of. The disposition thus affirms the High Court's decision while permitting future legal contestation on substantive points and limitation, leaving procedural and substantive issues available for reconsideration before the appropriate authority.

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