(1) In order to take action against the tax advantage, the Deputy Commissioner of Taxes shall issue a notice to the assessee specifying the following issues, namely:—

(a) the Deputy Commissioner of Taxes has reason to believe that the assessee has taken advantage of the tax through abuse of the tax arrangement;

(b) where applicable, details of the measures intended to be taken, including the purpose of the adjustment;

(c) to appear before the Deputy Commissioner of Taxes on the date specified in the notice to the assessee;

(d) submission of statements, documents and information necessary for decision on receipt of tax advantage.

(2) For the adjustment of tad benefit, the assessee shall be given an opportunity of being heard and be allowed at least 30 (thirty) days from the date on which notice was served on the assessee to the date of hearing.

(3) The Deputy Commissioner of Taxes shall issue an adjustment order subject to the prior approval of the Commissioner of Taxes after considering all the information presented to him on the basis of records, documents submitted by the assessee and presented during the hearing and shall notify the same to the assessee within 30 (thirty) days from the date of issuance of the order of adjustment.