Chandrakant Dharia v. ITO

469 ITR 262Reported decision#3529 most cited

What is Chandrakant Dharia v. ITO authority for?

An adverse assessment order cannot be passed without granting the taxpayer an opportunity for a personal hearing, especially when income is to be varied based on submitted evidence.

34

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2025 to 2025.

Also referred to as

Chandrakant Dharia v. ITO · Nikhil Chandrakant Dharia Vs ITO · adverse order · personal hearing · principles of natural justice · draft assessment order · show cause notice · varied income · opportunity of hearing

Sections most often in play

Section 1961Section 1963Section 153CSection 250Section 253(1)Section 143(3)Section 153ASection 253(1) of the Income-tax Act

Issues it is cited on

section 253(1)draft assessment orderfirst appealdelay in filing appealfinal assessment ordersection 153csection 153asection 250personcompanynfacsection 143(3)

Judgments citing Chandrakant Dharia v. ITO

DEVI WINES,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

Accordingly. The grounds thus stands partly allowed for statistical purposes

ITA 32/PAN/2024[2018-19]Status: DisposedITAT Panaji03 Jul 2025AY 2018-19

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: NoneFor Respondent: Capt. Pradeep Arya [‘Ld. DR’]
Section 153CSection 250Section 253(1)

…Consequently it was held that, an adverse order cannot be passed without granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 10. The denial of personal hearing was agitated in Writ in ‘Balraj Hire Purchase (P.) Ltd. Vs NFAC’ [2021, 128 taxmann.com 190 (Del)] wherein Revenue contended that assessee’s reply to show cause notice-cum-draft assessment order was considered, hence the outcome would have been same even if AO had granted a personal hearing. The Hon’ble Court…

DEVI WINES,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

Accordingly. The grounds thus stands partly allowed for statistical purposes

ITA 31/PAN/2024[2017-18]Status: DisposedITAT Panaji03 Jul 2025AY 2017-18

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: NoneFor Respondent: Capt. Pradeep Arya [‘Ld. DR’]
Section 153CSection 250Section 253(1)

…Consequently it was held that, an adverse order cannot be passed without granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 10. The denial of personal hearing was agitated in Writ in ‘Balraj Hire Purchase (P.) Ltd. Vs NFAC’ [2021, 128 taxmann.com 190 (Del)] wherein Revenue contended that assessee’s reply to show cause notice-cum-draft assessment order was considered, hence the outcome would have been same even if AO had granted a personal hearing. The Hon’ble Court…

DEVI WINES,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

Accordingly. The grounds thus stands partly allowed for statistical purposes

ITA 30/PAN/2024[2016-17]Status: DisposedITAT Panaji03 Jul 2025AY 2016-17

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: NoneFor Respondent: Capt. Pradeep Arya [‘Ld. DR’]
Section 153CSection 250Section 253(1)

…Consequently it was held that, an adverse order cannot be passed without granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 10. The denial of personal hearing was agitated in Writ in ‘Balraj Hire Purchase (P.) Ltd. Vs NFAC’ [2021, 128 taxmann.com 190 (Del)] wherein Revenue contended that assessee’s reply to show cause notice-cum-draft assessment order was considered, hence the outcome would have been same even if AO had granted a personal hearing. The Hon’ble Court…

DEVI WINES,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

Accordingly. The grounds thus stands partly allowed for statistical purposes

ITA 29/PAN/2024[2015-16]Status: DisposedITAT Panaji03 Jul 2025AY 2015-16

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: NoneFor Respondent: Capt. Pradeep Arya [‘Ld. DR’]
Section 153CSection 250Section 253(1)

…Consequently it was held that, an adverse order cannot be passed without granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 10. The denial of personal hearing was agitated in Writ in ‘Balraj Hire Purchase (P.) Ltd. Vs NFAC’ [2021, 128 taxmann.com 190 (Del)] wherein Revenue contended that assessee’s reply to show cause notice-cum-draft assessment order was considered, hence the outcome would have been same even if AO had granted a personal hearing. The Hon’ble Court…

DEVI WINES,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

Accordingly. The grounds thus stands partly allowed for statistical purposes

ITA 28/PAN/2024[2014-15]Status: DisposedITAT Panaji03 Jul 2025AY 2014-15

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: NoneFor Respondent: Capt. Pradeep Arya [‘Ld. DR’]
Section 153CSection 250Section 253(1)

…Consequently it was held that, an adverse order cannot be passed without granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 10. The denial of personal hearing was agitated in Writ in ‘Balraj Hire Purchase (P.) Ltd. Vs NFAC’ [2021, 128 taxmann.com 190 (Del)] wherein Revenue contended that assessee’s reply to show cause notice-cum-draft assessment order was considered, hence the outcome would have been same even if AO had granted a personal hearing. The Hon’ble Court…

DEVI WINES,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

Accordingly. The grounds thus stands partly allowed for statistical purposes

ITA 27/PAN/2024[2013-14]Status: DisposedITAT Panaji03 Jul 2025AY 2013-14

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: NoneFor Respondent: Capt. Pradeep Arya [‘Ld. DR’]
Section 153CSection 250Section 253(1)

…Consequently it was held that, an adverse order cannot be passed without granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 10. The denial of personal hearing was agitated in Writ in ‘Balraj Hire Purchase (P.) Ltd. Vs NFAC’ [2021, 128 taxmann.com 190 (Del)] wherein Revenue contended that assessee’s reply to show cause notice-cum-draft assessment order was considered, hence the outcome would have been same even if AO had granted a personal hearing. The Hon’ble Court…

ASHIRWAD WINES,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

ITA 41/PAN/2024[2018-19]Status: DisposedITAT Panaji01 Jul 2025AY 2018-19

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr BS Balachandran [‘Ld. AR’]For Respondent: Capt. Pradeep Arya [‘Ld. DR’]
Section 153CSection 250Section 253(1)

…Ashirwad Wines Vs DCIT ITA No 037 to 041/PAN/2024 AY : 2013-14 to 2018-19 granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 10. The denial of personal hearing was agitated in Writ in ‘Balraj Hire Purchase (P.) Ltd. Vs NFAC’ [2021, 128 taxmann.com 190 (Del)] wherein Revenue contended that assessee’s reply to show cause notice- cum-draft assessment order was considered, hence the outcome would have been same even if AO had granted a personal hearing. The Hon’ble Cour…

ASHIRWAD WINES,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

ITA 40/PAN/2024[2017-18]Status: DisposedITAT Panaji01 Jul 2025AY 2017-18

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr BS Balachandran [‘Ld. AR’]For Respondent: Capt. Pradeep Arya [‘Ld. DR’]
Section 153CSection 250Section 253(1)

…Ashirwad Wines Vs DCIT ITA No 037 to 041/PAN/2024 AY : 2013-14 to 2018-19 granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 10. The denial of personal hearing was agitated in Writ in ‘Balraj Hire Purchase (P.) Ltd. Vs NFAC’ [2021, 128 taxmann.com 190 (Del)] wherein Revenue contended that assessee’s reply to show cause notice- cum-draft assessment order was considered, hence the outcome would have been same even if AO had granted a personal hearing. The Hon’ble Cour…

ASHIRWAD WINES,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

ITA 39/PAN/2024[2016-17]Status: DisposedITAT Panaji01 Jul 2025AY 2016-17

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr BS Balachandran [‘Ld. AR’]For Respondent: Capt. Pradeep Arya [‘Ld. DR’]
Section 153CSection 250Section 253(1)

…Ashirwad Wines Vs DCIT ITA No 037 to 041/PAN/2024 AY : 2013-14 to 2018-19 granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 10. The denial of personal hearing was agitated in Writ in ‘Balraj Hire Purchase (P.) Ltd. Vs NFAC’ [2021, 128 taxmann.com 190 (Del)] wherein Revenue contended that assessee’s reply to show cause notice- cum-draft assessment order was considered, hence the outcome would have been same even if AO had granted a personal hearing. The Hon’ble Cour…

ASHIRWAD WINES,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

ITA 38/PAN/2024[2014-15]Status: DisposedITAT Panaji01 Jul 2025AY 2014-15

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr BS Balachandran [‘Ld. AR’]For Respondent: Capt. Pradeep Arya [‘Ld. DR’]
Section 153CSection 250Section 253(1)

…Ashirwad Wines Vs DCIT ITA No 037 to 041/PAN/2024 AY : 2013-14 to 2018-19 granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 10. The denial of personal hearing was agitated in Writ in ‘Balraj Hire Purchase (P.) Ltd. Vs NFAC’ [2021, 128 taxmann.com 190 (Del)] wherein Revenue contended that assessee’s reply to show cause notice- cum-draft assessment order was considered, hence the outcome would have been same even if AO had granted a personal hearing. The Hon’ble Cour…

ASHIRWAD WINES,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE , BELAGAVI

ITA 37/PAN/2024[2013-14]Status: DisposedITAT Panaji01 Jul 2025AY 2013-14

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr BS Balachandran [‘Ld. AR’]For Respondent: Capt. Pradeep Arya [‘Ld. DR’]
Section 153CSection 250Section 253(1)

…Ashirwad Wines Vs DCIT ITA No 037 to 041/PAN/2024 AY : 2013-14 to 2018-19 granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 10. The denial of personal hearing was agitated in Writ in ‘Balraj Hire Purchase (P.) Ltd. Vs NFAC’ [2021, 128 taxmann.com 190 (Del)] wherein Revenue contended that assessee’s reply to show cause notice- cum-draft assessment order was considered, hence the outcome would have been same even if AO had granted a personal hearing. The Hon’ble Cour…

SHRI BASAVRAJ SHIVAPPA BHATE,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

ITA 47/PAN/2024[2018-19]Status: DisposedITAT Panaji18 Jun 2025AY 2018-19

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr BS Balachandran [‘Ld. AR’]For Respondent: Mr Satish M [‘Ld. DR’]
Section 153ASection 153CSection 250Section 253(1)

…Consequently it was held that, an adverse order cannot be passed without granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 12. Further in a case where a show cause notice- cum-draft assessment order was replied by written submission accompanying therewith a request for personal hearing before passing final assessment order. The order of assessment however was passed ITAT-Panaji Page 9 of 12 BS Bhate & Others Vs DCIT AY : 2013-14 to 2018-19 without according a p…

SHRI BASAVARAJ SHIVAPPA BHATE,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

ITA 46/PAN/2024[2017-18]Status: DisposedITAT Panaji18 Jun 2025AY 2017-18

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr BS Balachandran [‘Ld. AR’]For Respondent: Mr Satish M [‘Ld. DR’]
Section 153ASection 153CSection 250Section 253(1)

…Consequently it was held that, an adverse order cannot be passed without granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 12. Further in a case where a show cause notice- cum-draft assessment order was replied by written submission accompanying therewith a request for personal hearing before passing final assessment order. The order of assessment however was passed ITAT-Panaji Page 9 of 12 BS Bhate & Others Vs DCIT AY : 2013-14 to 2018-19 without according a p…

SHRI BASAVARAJ SHIVAPPA BHATE,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

ITA 45/PAN/2024[2016-17]Status: DisposedITAT Panaji18 Jun 2025AY 2016-17

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr BS Balachandran [‘Ld. AR’]For Respondent: Mr Satish M [‘Ld. DR’]
Section 153ASection 153CSection 250Section 253(1)

…Consequently it was held that, an adverse order cannot be passed without granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 12. Further in a case where a show cause notice- cum-draft assessment order was replied by written submission accompanying therewith a request for personal hearing before passing final assessment order. The order of assessment however was passed ITAT-Panaji Page 9 of 12 BS Bhate & Others Vs DCIT AY : 2013-14 to 2018-19 without according a p…

SHRI BASAVARAJ SHIVAPPA BHATE,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

ITA 44/PAN/2024[2015-16]Status: DisposedITAT Panaji18 Jun 2025AY 2015-16

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr BS Balachandran [‘Ld. AR’]For Respondent: Mr Satish M [‘Ld. DR’]
Section 153ASection 153CSection 250Section 253(1)

…Consequently it was held that, an adverse order cannot be passed without granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 12. Further in a case where a show cause notice- cum-draft assessment order was replied by written submission accompanying therewith a request for personal hearing before passing final assessment order. The order of assessment however was passed ITAT-Panaji Page 9 of 12 BS Bhate & Others Vs DCIT AY : 2013-14 to 2018-19 without according a p…

SHRI BASAVRAJ SHIVAPPA BHATE,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

ITA 43/PAN/2024[2014-15]Status: DisposedITAT Panaji18 Jun 2025AY 2014-15

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr BS Balachandran [‘Ld. AR’]For Respondent: Mr Satish M [‘Ld. DR’]
Section 153ASection 153CSection 250Section 253(1)

…Consequently it was held that, an adverse order cannot be passed without granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 12. Further in a case where a show cause notice- cum-draft assessment order was replied by written submission accompanying therewith a request for personal hearing before passing final assessment order. The order of assessment however was passed ITAT-Panaji Page 9 of 12 BS Bhate & Others Vs DCIT AY : 2013-14 to 2018-19 without according a p…

SHRI BASAVRAJ SHIVAPPA BHATE,BELAGAVI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

ITA 42/PAN/2024[2013-14]Status: DisposedITAT Panaji18 Jun 2025AY 2013-14

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr BS Balachandran [‘Ld. AR’]For Respondent: Mr Satish M [‘Ld. DR’]
Section 153ASection 153CSection 250Section 253(1)

…Consequently it was held that, an adverse order cannot be passed without granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 12. Further in a case where a show cause notice- cum-draft assessment order was replied by written submission accompanying therewith a request for personal hearing before passing final assessment order. The order of assessment however was passed ITAT-Panaji Page 9 of 12 BS Bhate & Others Vs DCIT AY : 2013-14 to 2018-19 without according a p…

AKASH PEG BAR,BELGAUM vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

ITA 67/PAN/2023[2018-19]Status: DisposedITAT Panaji18 Jun 2025AY 2018-19

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr BS Balachandran [‘Ld. AR’]For Respondent: Mr Satish M [‘Ld. DR’]
Section 153ASection 153CSection 250Section 253(1)

…Consequently it was held that, an adverse order cannot be passed without granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 12. Further in a case where a show cause notice- cum-draft assessment order was replied by written submission accompanying therewith a request for personal hearing before passing final assessment order. The order of assessment however was passed ITAT-Panaji Page 9 of 12 BS Bhate & Others Vs DCIT AY : 2013-14 to 2018-19 without according a p…

AKASH PEG BAR,BELGAUM vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

ITA 66/PAN/2023[2017-18]Status: DisposedITAT Panaji18 Jun 2025AY 2017-18

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr BS Balachandran [‘Ld. AR’]For Respondent: Mr Satish M [‘Ld. DR’]
Section 153ASection 153CSection 250Section 253(1)

…Consequently it was held that, an adverse order cannot be passed without granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 12. Further in a case where a show cause notice- cum-draft assessment order was replied by written submission accompanying therewith a request for personal hearing before passing final assessment order. The order of assessment however was passed ITAT-Panaji Page 9 of 12 BS Bhate & Others Vs DCIT AY : 2013-14 to 2018-19 without according a p…

AKASH PEG BAR,BELGAUM vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

ITA 65/PAN/2023[2016-17]Status: DisposedITAT Panaji18 Jun 2025AY 2016-17

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr BS Balachandran [‘Ld. AR’]For Respondent: Mr Satish M [‘Ld. DR’]
Section 153ASection 153CSection 250Section 253(1)

…Consequently it was held that, an adverse order cannot be passed without granting an opportunity of personal hearing to the taxpayer. A similar ratio also reiterated by the Hon’ble Jurisdictional Bombay High Court in ‘Nikhil Chandrakant Dharia Vs ITO’ [2024, 469 ITR 262]. 12. Further in a case where a show cause notice- cum-draft assessment order was replied by written submission accompanying therewith a request for personal hearing before passing final assessment order. The order of assessment however was passed ITAT-Panaji Page 9 of 12 BS Bhate & Others Vs DCIT AY : 2013-14 to 2018-19 without according a p…

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