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    <title>2023 (1) TMI 1524 - GUJARAT HIGH COURT</title>
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    <description>A reassessment order under Section 148A(d) and the consequential notice under Section 148 were unsustainable where the Assessing Officer did not consider the assessee&#039;s reply and failed to clearly communicate rejection of an adjournment request or fix a definite further hearing date. The HC held that procedural fairness requires the assessee to be informed, by an effective mode such as e-mail or portal, either of the reasons for rejecting adjournment or of the specific date for further opportunity. As the reply was ignored and no clear opportunity was granted, the initiation of reassessment was quashed and the matter remitted for fresh consideration of the reply after hearing the assessee.</description>
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      <description>A reassessment order under Section 148A(d) and the consequential notice under Section 148 were unsustainable where the Assessing Officer did not consider the assessee&#039;s reply and failed to clearly communicate rejection of an adjournment request or fix a definite further hearing date. The HC held that procedural fairness requires the assessee to be informed, by an effective mode such as e-mail or portal, either of the reasons for rejecting adjournment or of the specific date for further opportunity. As the reply was ignored and no clear opportunity was granted, the initiation of reassessment was quashed and the matter remitted for fresh consideration of the reply after hearing the assessee.</description>
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