Ex-parte assessment under Section 147 quashed; petitioner allowed to respond to Section 148A(b) notice for fair hearing

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....The HC quashed the ex-parte assessment order passed under Section 147, rejecting the petitioner's claim that business cessation prevented activation of the PAN and opportunity to reply under Section 148A(b). Exercising discretion in the interest of justice, the court remanded the matter to the first respondent for fresh adjudication, permitting the petitioner to respond to the Section 148A(b) notice. This ensures procedural fairness by allowing the petitioner to furnish documents and be heard before further proceedings.....