Assessing Officer reopened assessment of assessee for reasons that it had not deducted tax at source under section 195 on amount paid to foreign companies towards multimedia charges which warranted reopening of assessment. He also rejected objections raised by assessee holding that there was tangible material evidence made available to resort to reassessment proceedings. Single Judge of High Court directed assessee to participate in reassessment proceedings and to place all materials and legal issues before Assessing Officer for consideration  On appeal division bench held that   since a final order in reassessment proceedings was yet to be passed, direction issued by Single Judge was proper and did not call for any interference. Assessing Officer was directed to afford an opportunity of hearing to assessee and after considering all objections raised pass appropriate order on merits.  (AY. 2004-05)