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Validity of reopening of assessment - grievance raised that the objections raised were not specifically dealt - Procedure prescribed u/s 148A followed or not? - The Central Board of Direct Taxes (CBDT) after the decision of Supreme Court in Ashish Agarwal issued guidelines for issuance of notice u/s 148 - The High court found that the impugned order did not adhere to the prescribed procedures u/s 148A of the Act and the CBDT guidelines. The order was quashed, and the matter was remitted back to the respondent for further proceedings in accordance with the law. - Consequently, the HC remanded the matter back to proceed with notice u/s 148-A(b) in accordance with law.