Reassessment Notice u/s 148 Violates Natural Justice by Denying Assessee Opportunity to Contest Reopening.

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....Reassessment u/s. 147 vide notice of u/s. 148 - As per the settled law, the Assessing Officer should have given opportunity to the assessee to contest the reopening and file objections against the reasons recorded. However, in this case, the reopening was done on the last date of limitation period, therefore, no opportunity to file objections has been granted to the assessee which violates the principles of natural justice. - AT....