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of ITAT quashed reassessment proceedings where AO provided only 5 days to assessee for filing explanation under s.148A(b). Following judicial precedent that established 7 days as unreasonably short notice period violating natural justice principles, the Tribunal determined 5-day period was inadequate. Matter remanded to AO with directions to provide proper opportunity of being heard to assessee firm per s.148A(b) requirements before proceeding with fresh assessment. Tribunal emphasized compliance with procedural fairness in reopening assessments, particularly regarding reasonable time for response. Appeal allowed for statistical purposes.
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