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Validity of reopening of assessment u/s 147 - Purchase the immovable property on which TDS has been deducted - TDS statement (Form 26QB) shows the amount of purchase of property twice - The notice to the petitioner has been based only for the aforesaid reasons, whereas the impugned order would further add new reasons for the order. The petitioner had not been given an opportunity to answer and explain the same. - Proceedings set aside - Petitioner / assessee allowed to submit the reply and opportunity of personal hearing shall be given to the assessee - HC