The assessee filed a writ petition against the notice issued under section 148A(b) of the Income-tax Act, 1961 on the ground that adequate opportunity was not granted though the statute specified that a minimum of seven days’ time should be granted. The court dismissed the writ petition observing that rejection of the assessee’s objection to the notice under section 148A(b) did not mean that any final reassessment order was passed and a demand was raised, that the assessee would have opportunity during the reassessment proceedings to establish his case and to make out a case for dropping the reassessment proceedings and that it could not be called a case of violation of principles of natural justice. On appeal, The division Bench held that the assessee was to be granted an opportunity by the Assessing Officer in terms of section 148A(b). The notice issued under section 148 should not be enforced and fresh action could be initiated in accordance with law. The show-cause notice issued under section 148A(b) was received online by the assessee on March 17, 2022 and the order under section 148A(d) had been passed on March 29, 2022 and according to the Assessing Officer, the assessee had not produced any document to substantiate his claim. March 17, 2022 was declared as a State holiday on account of Holi festival and March 18, 2022 (Friday) was also declared a holiday and March 19, 2022 and March 20, 2022 being Saturday and Sunday, the next working day was March 21, 2022. Therefore, the period of notice issued to the assessee could not be stated to be affording a reasonable and adequate opportunity to the assessee. The assessee had requested for copies of certain documents. The Assessing Officer before affording an opportunity of hearing should consider such representation and take a decision on the merits. The assessee should submit a fresh reply and was at liberty to also refer to the notice dated March 29, 2022 under section 148A(b). The Assessing Officer was to consider the documents produced by the assessee and pass a fresh order under section 148A(d). Matter remanded.(AY. 2018 -19)( SJ)