On a writ the Court held, that although, since the assessee had not replied to notices, the Assessing Officer could not be faulted for completing the assessment on best judgment basis in the facts and circumstances, it was clear that the assessment was made several years after the assessee had filed the return of income and on the basis of material unearthed in the course of search in 2012. When these facts and circumstances were considered cumulatively, it was appropriate that the assessee be provided an opportunity of being heard before the reassessment was concluded. Solely for this reason, the assessment order dated December 30, 2019 in respect of the assessment year 2013-2014 had to be quashed. The assessment order was to be treated as a show-cause notice. The Court directed the  assessee to  file a reply within 15 days from receipt of a copy thereof, where after, the Assessing Officer was to provide the assessee reasonable opportunity to be heard, including a personal hearing, and thereafter issue a fresh assessment order within two months.(SJ) (AY. 2013-14)