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of The HC set aside orders under Section 264 along with best judgment assessment orders under Sections 143 and 147, remanding the matter to the Assessing Officer for fresh consideration. The petitioner, originally a trust subsequently converted to a society, failed to participate in assessment proceedings claiming non-receipt of notices due to service on old PAN number following management name change. Despite petitioner's non-participation and failure to file reply or produce documentary evidence, the HC held that valuable rights under Section 264 should not be deprived merely due to non-participation. Considering practical difficulties arising from organizational conversion and management changes, the court granted one more opportunity in the interest of justice for fresh assessment proceedings.
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