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    <description>Pending appellate proceedings were directed to be revived so the assessee could pursue the challenge before the Commissioner (Appeals), including additional grounds on legality and limitation. Interim protection was also granted by directing that the assessment order not be acted upon during pendency of the restored appeal, and that the assessee be given hearing on advance notice. The Court did not decide the merits of the reassessment dispute in this order; it confined itself to restoring the appeal framework and preserving the assessee&#039;s position until the appeal is disposed of.</description>
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      <description>Pending appellate proceedings were directed to be revived so the assessee could pursue the challenge before the Commissioner (Appeals), including additional grounds on legality and limitation. Interim protection was also granted by directing that the assessment order not be acted upon during pendency of the restored appeal, and that the assessee be given hearing on advance notice. The Court did not decide the merits of the reassessment dispute in this order; it confined itself to restoring the appeal framework and preserving the assessee&#039;s position until the appeal is disposed of.</description>
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