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Issues: Whether a notice issued under Section 148A(b) of the Income-tax Act, 1961 is valid when it grants less than seven days to respond.
Analysis: The notice required a reply within a period shorter than seven days. The provision was treated as requiring a minimum response period of not less than seven days. Following the earlier coordinate bench decision on an identical question, the Court found no reason to differ and held that the impugned notice did not satisfy the statutory requirement.
Conclusion: The short notice under Section 148A(b) was invalid, and the challenge to it succeeded.
Ratio Decidendi: A notice under Section 148A(b) of the Income-tax Act, 1961 must provide the assessee not less than seven days to respond, and any notice granting a shorter period is unsustainable.