Natural justice in reassessment: failure to consider assessee's reply vitiates the notice and requires fresh adjudication

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....Non-consideration of the assessee's replies before forming belief under section 148A(3) violated natural justice and vitiated the reassessment order, because the order merely noted partial bank statements and did not examine the explanations or the commercial rationale and materials produced. The impugned order and consequential notice were quashed, and the matter was remitted for fresh consideration of the genuineness and creditworthiness of the transactions after granting a hearing and passing a reasoned order.....