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      <description>The assessment was set aside and remitted for fresh consideration because the petitioner had not effectively participated in the proceedings and sought an opportunity to file objections and documentary evidence. Although service of notice was found to have been effected and no illegality was recorded in the initiation of assessment, the Court accepted that further opportunity was required in the interests of justice. The respondent was directed to reconsider the matter on merits after allowing the petitioner to place a detailed reply and supporting records.</description>
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