Court Rules Reopening u/s 147 Invalid Due to Denial of Meaningful Hearing u/s 148A(d.

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....Reopening of assessment u/s 147 - denial of natural justice - order passed under Section 148A(d) - The legal principle that can be culled out from the aforementioned decisions is that the opportunity which is provided for under the scheme of the Act should be a meaningful and effective opportunity as such opportunity is not an empty formality. The assessee is entitled to be heard and such hearing should be a purposeful and effective hearing and not for the sake of showing as if a hearing was conducted. - HC....