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of Reopening of assessment - act of giving only 12 hours to file reply to the show cause notice by the respondents - When the show cause notice-cum-draft assessment order is issued to the petitioner, reasonable/adequate opportunity was required to be given to him. In the present case, adequate opportunity was not given to the petitioner and therefore only on this ground the petition deserves to be allowed. - AO may initiate any action from the stage from where it has been left - HC
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