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of Validity of Reopening of assessment - notice issued u/s 148A(d) entirely on the basis of information obtained from the Insight Portal in accordance with the risk management strategy of the Income Tax Department - Unless an assessee's response to the show cause notice is duly considered before a decision is taken to issue notice u/s 148, the statutory mandate of a prior show cause notice would be reduced to an empty formality. - The said order is hereby quashed. - HC
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