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    <description>Proper opportunity of hearing and quantification of the proposed addition were treated as necessary before completing assessment, where the taxpayer had already filed explanations and supporting material but sought further time to produce additional records. The assessment was completed on the basis that primary evidence, confirmations, and complete documentation were not furnished. The assessment order and consequential notices were set aside, and the matter was remitted to the enquiry stage under Section 143(2) of the Income-tax Act, 1961, with all contentions kept open for fresh consideration.</description>
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