High Court overturns assessment order u/s 147 due to inadequate response time in Show Cause Notice.

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....Reopening of assessment u/s 147 - Lack of full disclosures - Time given vide SCN dated 13.09.2021 is too short - To be noted, vide paragraph 3 of the SCN, writ petitioner-assessee was called upon to respond by 23:59 hours on 16.09.2021. 13.09.2021 is a Monday and obviously 16.09.2021 is Wednesday and that fairly three working days. It is clearly insufficient. - the impugned assessment order made by the first respondent is set aside on the grounds of lack of opportunity / specificity - Matter restored back - HC....