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“opportunity of being heard”

Natural JusticeAudi Alteram PartemAudi Alteram Partem22,508 judgments

The decision most relied on for opportunity of being heard is CIT v. Multiplan India Ltd. (38 ITD 320), cited in 2,267 judgments on BharatTax.

Leading authorities on opportunity of being heard

CIT v. Multiplan India Ltd.
38 ITD 320 · 1991 · ITAT
2,267
citing judgments

An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

CIT v. B.N. Bhattacharya & Another
118 ITR 461 · 1997 · Supreme Court
1,656
citing judgments

Appealing a tax assessment requires more than just filing the appeal; it involves actively pursuing it. The assessee must effectively engage with the appellate process.

Rashmikant Kundalia v. Union of India
54 Taxmann.com 200 · 2015 · High Court
702
citing judgments

Section 234E, levying late fees for delayed filing of TDS statements under section 200(3), is constitutionally valid and constitutes a compensatory fee, not a punitive penalty. Before treating any person as an assessee-in-default, an opportunity of being heard must be provided.

Tin Box Company v. CIT
249 ITR 216 · 2001 · Supreme Court
624
citing judgments

When an issue is remitted to the Assessing Officer for fresh adjudication, the AO must conduct a de novo examination and provide the assessee a full opportunity of being heard. The assessee is bound to comply with the notices issued by the AO.

CIT v. Vikas Polymers
341 ITR 537 · 2012 · High Court
318
citing judgments

An assessment order is not erroneous and prejudicial under Section 263 merely because the Assessing Officer did not record an enquiry and its satisfactory answer in the assessment order, provided such an enquiry was conducted. For revision under Section 263, the Commissioner must also provide the assessee an opportunity of being heard and examine their explanation.

Commissioner of Income Tax Madras v. Chenniyappa Mudiliar
1 SCC 591 · 1985 · Reported
225
citing judgments

The appellate tribunal must render a proper decision on both facts and law, disposing of an appeal on its merits rather than dismissing it solely due to the appellant's absence. This obligation is derived from Section 33(4) of the Income Tax Act, 1922, and reflects principles of natural justice.

ITO v. M. Pirai Choodi
334 ITR 262 · 2011 · Supreme Court
211
citing judgments

If an assessee was denied an adequate opportunity of being heard, including the right to cross-examine a witness, the assessment should be set aside and restored for fresh adjudication after affording due opportunity, even if the assessee failed to appear at an appellate stage. The Tribunal, in the interest of justice, should ensure such matters are re-adjudicated.

Indian & Eastern Newspaper Society v. CIT
119 ITR 996 · 1979 · Supreme Court
205
citing judgments

An assessment cannot be reopened under Section 147/148 based on a mere change of opinion by the Assessing Officer on material already considered during the original assessment, clarifying the scope of 'escaped assessment'.

Judgments citing opportunity of being heard

Venkata Prasad Pulipati, Amaravathi vs. Income-Tax Officer, Ward-2(1), Guntur

In the result, the appeal filed by the assessee is allowed in terms of our aforesaid observations

ITA 612/VIZ/2025[2016-17]Status: DisposedITAT Visakhapatnam19 Dec 2025AY 2016-17

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.612/Viz/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Venkata Prasad Pulipati, Vs. Income Tax Officer, Amaravathi. Ward-2(1), Pan: Asapp8796L Guntur. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri I. Kama Sastry, Ca राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 03/12/2025 Hearing: घोषणा की तारीख/Date Of 19/12/2025 Pronouncement: आदेश / Order

For Appellant: Shri I. Kama Sastry, CAFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 147Section 148Section 148ASection 149(1)(b)Section 151Section 30Section 69

approval of specified authority, with respect to the information which suggests that the income chargeable to tax has escaped assessment; (b) provide an opportunity of being heard to the assessee, with the prior approval of specified authority, by serving upon him a notice to show cause within such time ... approval of specified authority, with respect to the information which suggests that the income chargeable to tax has escaped assessment; (ii) provide an opportunity of being heard to the assessee, with the prior approval of specified authority; (iii) consider the reply of the assessee furnished, if any, in response

Vulli Radhakrishna, Tuni vs. Income Tax Officer, Ward-1, Tuni

ITA 359/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam19 Dec 2025AY 2015-16

Bench: Shri Ravish Sood & Shri Balakrishnan S.आ.अपी.सं /Ita No.359/Viz/2025 (िनधा"रण वष"/Assessment Year: 2015-16) Vulli Radhakrishna, Vs. Income Tax Officer, Tuni. Ward-1, Pan: Aegpv1751H Tuni. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri Gvn Hari, Advocate राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of 04/12/2025 Hearing: घोषणा की तारीख/Date Of 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, Jm: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 17/03/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short “A.O.”) Under Section 147 R.W.S 144 R.W.S 144B Of The Income Tax Act, 1961 (For Short “The Act”) Dated 26/03/2022 For Assessment Year (Ay) 2015-16. 2 Vulli Radhakrishna Vs. Ito

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 147Section 148Section 151ASection 69A

aside the matter to the file of the AO with a direction to re-adjudicate the subject issues afresh after affording a reasonable opportunity of being heard to the assessee. 19. Resultantly, the appeal filed by the assessee is allowed for statistical purposes in terms of our aforesaid observations. Order

Shree Vindhya Cast Coaters Limited, Jalgaon vs. Deputy Commissioner of Income Tax, Circle - 1, Jalgaon

In the result, the appeals of assessee in ITA Nos

ITA 1121/PUN/2025[2022-23]Status: DisposedITAT Pune19 Dec 2025AY 2022-23

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

For Appellant: Shri Anand Karnani (Virtual)For Respondent: Smt. Indira R. Adakil
Section 234E

filing of all the six appeals before him and decide the appeals on merits, as per facts and law after giving due opportunity of being heard to the assessee. The assessee is also hereby directed to make its submissions, as may be required/called upon on the appointed date without seeking

Shree Vindhya Cast Coaters Limited, Jalgaon vs. Deputy Commissioner of Income Tax, Circle - 1, Jalgaon

In the result, the appeals of assessee in ITA Nos

ITA 1120/PUN/2025[2022-23]Status: DisposedITAT Pune19 Dec 2025AY 2022-23

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.1116 To 1121/Pun/2025 निर्धारण वर्ष / Assessment Years : 2020-21 To 2022-23 Shree Vindhya Cast Coaters Limited, Somani Nagar, Duskheda B.O., Bhusawal, Jalgaon-425203 Vs. Deputy Commissioner Of Income Tax, Cpc-Tds Pan: Aaacs8089A अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Department By : Date Of Hearing : Date Of Pronouncement : Shri Anand Karnani (Virtual) Smt. Indira R. Adakil 01-12-2025 19-12-2025 आदेश / Order Per Astha Chandra, Jm : The Above Six Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 20.02.2025 & 21.02.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac"] Pertaining To

For Appellant: Department byFor Respondent: Date of hearing
Section 234E

filing of all the six appeals before him and decide the appeals on merits, as per facts and law after giving due opportunity of being heard to the assessee. The assessee is also hereby directed to make its submissions, as may be required/called upon on the appointed date without seeking

Shree Vindhya Cast Coaters Limited, Jalgaon vs. Deputy Commissioner of Income Tax, Circle - 1, Jalgaon

In the result, the appeals of assessee in ITA Nos

ITA 1119/PUN/2025[2021-22]Status: DisposedITAT Pune19 Dec 2025AY 2021-22

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripoteआयकर अपील सं. / Ita Nos.1116 To 1121/Pun/2025 निर्धारण वर्ष / Assessment Years : 2020-21 To 2022-23 Shree Vindhya Cast Coaters Limited, Somani Nagar, Duskheda B.O., Bhusawal, Jalgaon-425203 Vs. Deputy Commissioner Of Income Tax, Cpc-Tds Pan: Aaacs8089A अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Anand Karnani (Virtual) Department By : Smt. Indira R. Adakil Date Of Hearing : 01-12-2025 Date Of Pronouncement : 19-12-2025 आदेश / Order Per Astha Chandra, Jm : The Above Six Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 20.02.2025 & 21.02.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac"] Pertaining To

For Appellant: Shri Anand Karnani (Virtual)For Respondent: Smt. Indira R. Adakil
Section 234E

filing of all the six appeals before him and decide the appeals on merits, as per facts and law after giving due opportunity of being heard to the assessee. The assessee is also hereby directed to make its submissions, as may be required/called upon on the appointed date without seeking

Shree Vindhya Cast Coaters Limited, Jalgaon vs. Deputy Commissioner of Income Tax, Circle - 1, Jalgaon

In the result, the appeals of assessee in ITA Nos

ITA 1118/PUN/2025[2021-22]Status: DisposedITAT Pune19 Dec 2025AY 2021-22

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

For Appellant: Shri Anand Karnani (Virtual)For Respondent: Smt. Indira R. Adakil
Section 234E

filing of all the six appeals before him and decide the appeals on merits, as per facts and law after giving due opportunity of being heard to the assessee. The assessee is also hereby directed to make its submissions, as may be required/called upon on the appointed date without seeking

Shree Vindhya Cast Coaters Limited, Jalgaon vs. Deputy Commissioner of Income Tax, Circle-1, Jalgaon

In the result, the appeals of assessee in ITA Nos

ITA 1117/PUN/2025[2021-22]Status: DisposedITAT Pune19 Dec 2025AY 2021-22

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

For Appellant: Shri Anand Karnani (Virtual)For Respondent: Smt. Indira R. Adakil
Section 234E

filing of all the six appeals before him and decide the appeals on merits, as per facts and law after giving due opportunity of being heard to the assessee. The assessee is also hereby directed to make its submissions, as may be required/called upon on the appointed date without seeking

Shree Vindhya Cast Coaters Limited, Jalgaon vs. Deputy Commissioner of Income Tax, Income Tax Office, B.J.Market

In the result, the appeals of assessee in ITA Nos

ITA 1116/PUN/2025[2020-21]Status: DisposedITAT Pune19 Dec 2025AY 2020-21

Bench: Ms. Astha Chandra & Shree Dr. Dipak P. Ripote

For Appellant: Shri Anand Karnani (Virtual)For Respondent: Smt. Indira R. Adakil
Section 234E

filing of all the six appeals before him and decide the appeals on merits, as per facts and law after giving due opportunity of being heard to the assessee. The assessee is also hereby directed to make its submissions, as may be required/called upon on the appointed date without seeking

Madhur Balasaheb Patil, Pune vs. ITO Ward 8(3), Pune

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 1010/PUN/2025[2014-15]Status: DisposedITAT Pune19 Dec 2025AY 2014-15

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Divyesh TripathiFor Respondent: Shri Vidya Ratna Kishore
Section 142(1)Section 144Section 145(3)Section 147Section 148Section 151

assessee to substantiate her case by filing the requisite details and decide the issue as per fact and law after providing due opportunity of being heard to the assessee. The assessee is also hereby directed to submit the requisite details before the Ld. CIT(A) / NFAC on the appointed date

Madhur Balasaheb Patil, Pune vs. ITO Ward8(3), Pune

In the result, both the appeals filed by the assessee are allowed for statistical purposes

ITA 1009/PUN/2025[2013-14]Status: DisposedITAT Pune19 Dec 2025AY 2013-14

Bench: Shri R. K. Panda & Ms. Astha Chandra

For Appellant: Shri Divyesh TripathiFor Respondent: Shri Vidya Ratna Kishore
Section 142(1)Section 144Section 145(3)Section 147Section 148Section 151

assessee to substantiate her case by filing the requisite details and decide the issue as per fact and law after providing due opportunity of being heard to the assessee. The assessee is also hereby directed to submit the requisite details before the Ld. CIT(A) / NFAC on the appointed date

Ankitjain, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

In the result, the appeal of the assessee is allowed in

ITA 913/HYD/2025[2018-19]Status: DisposedITAT Hyderabad19 Dec 2025AY 2018-19

Bench: Shri Ravish Sood & Shri Madhusudan Sawdia

For Appellant: Shri K.A. Sai Prasad, CA
Section 115BSection 147Section 148Section 148ASection 292CSection 69

type Information Value Remarks Unaccounted Investment 17,88,750 (On Money Given \Unaccounted Investment 14,89,150 jOn Money Given 3. Thus, an opportunity of being heard as per provision of section 148A(b) of the Income Tax Act,1961 was provided to the assessee with Prior approval from competent

Amara Raja Energy and Mobility Limited, Tirupati vs. DCIT., Circle-1(1), Tirupati

In the result, appeal of the Assessee is dismissed

ITA 791/HYD/2025[2021-2022]Status: DisposedITAT Hyderabad19 Dec 2025AY 2021-2022

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.791/Hyd/2025 Assessment Year 2021-2022 Amara Raja Energy & Mobility Limited, The Dcit, Circle-1(1), Vs. Tirupati – 517 520. Tirupati Pan Aabca9264E (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca E Phalguna Kumar राज" व "ारा /Revenue By: Sri Pavan Kumar Beerla, Cit-Dr

For Appellant: CA E Phalguna KumarFor Respondent: Sri Pavan Kumar Beerla, CIT-DR
Section 143(3)Section 263

direction to the Assessing Officer to verify the issue as discussed in the impugned order in accordance with law, after affording reasonable opportunity of being heard to the assessee. 4. Before the Tribunal, the learned Authorised Representative of the Assessee has submitted that during the course of scrutiny assessment

Rukmini Priyadarshini Pamidi, Hyderabad vs. ITO., Ward-12(1), Hyderabad

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 714/HYD/2025[2013-14]Status: DisposedITAT Hyderabad19 Dec 2025AY 2013-14

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.714/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2013-14) Smt. Rukmini Vs. Income Tax Officer Priyadarshini Pamidi Ward 12(1) Hyderabad Hyderabad Pan:Alrpa4097P (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 11/12/2025 घोषणा की तारीख/Pronouncement: 19/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Shri S. Arun Kumar, Sr. DR

Rukmini Priyadarshini Pamidi Authority with a direction to adjudicate the matter afresh on merits, after providing one more opportunity of being heard to the assessee. Pursuant to the said directions, the First Appellate Authority initiated remand proceedings. However, the First Appellate Authority, dismissed the appeal of the assessee ... adjudicate the appeal afresh on merits, after considering the outcome of the remand report in the connected case and after providing reasonable opportunity of being heard to the assessee. The assessee is directed to cooperate fully in the appellate proceedings. The First Appellate Authority is at liberty to pass

Sanjeev Kumar Nalam, Hyderabad vs. ITO, Ward-1, Nirmal

In the result, the appeal of the assessee is allowed

ITA 669/HYD/2025[2017-18]Status: DisposedITAT Hyderabad19 Dec 2025AY 2017-18

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.669/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Shri Sanjeev Kumar Nalam Vs. Income Tax Officer Hyderabad Ward – 1 Pan:Avdpn0497L Adilabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri S. Rama Rao, Advocate राज" व "ारा/Revenue By:: Shri Waseem Ur Rehman, Sr.Dr सुनवाई की तारीख/Date Of Hearing: 03/12/2025 घोषणा की तारीख/Pronouncement: 19/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri S. Rama Rao, AdvocateFor Respondent: : Shri Waseem UR Rehman, Sr.DR
Section 147Section 148Section 148ASection 149(1)Section 151Section 153

approval of specified authority, with respect to the information which suggests that the income chargeable to tax has escaped assessment; (b) provide an opportunity of being heard to the assessee, with the prior approval of specified authority, by serving upon him a notice to show cause within such time ... approval of specified authority, with respect to the information which suggests that the income chargeable to tax has escaped assessment; (ii) provide an opportunity of being heard to the assessee, with the prior approval of specified authority; (iii) consider the reply of the assessee furnished, if any, in response

Satyam Gupta Araveeti, Prakasham District vs. ITO, Ward-1, Ongole

ITA 346/HYD/2025[2013-14]Status: DisposedITAT Hyderabad19 Dec 2025AY 2013-14
Section 115Section 115BSection 147Section 148Section 250Section 44ASection 69A

various persons/mills both within/outside the State. Needless to say, the AO shall, in the course of the set aside proceedings, afford a reasonable opportunity of being heard to the assessee, who shall, as per the extant law, remain at liberty to substantiate his claim based on fresh documentary evidence

Karthik Kumar Kyatham, Nizamabad vs. ITO, Ward-1, Adilabad

ITA 1658/HYD/2025[2020-21]Status: DisposedITAT Hyderabad19 Dec 2025AY 2020-21

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं / Ita No.1658/Hyd/2025

For Appellant: CA Phaneendra NagFor Respondent: B K Vishnu Priya, Sr. AR
Section 147Section 148Section 151ASection 24Section 249(3)Section 250Section 69

notice has to be issued only by the NFAC. 12. The Ld. CIT(A) erred in passing the order without giving proper reasonable opportunity of being heard to the assessee, which is incorrect and bad in law. 13. The Ld. CIT(A) erred in considering the fact that ... above mentioned information suggests that purchase consideration of Rs.31,50,000 has escaped assessment. 3. COME TAX DEPARTM Based on the above, an opportunity of being heard as per provision of section 148A(b) of the Income Tax act, 1961 was provided to the assesse vide show cause notice dated

Kaithi Govardhan Reddy (HUF), Hyderabad vs. Income Tax Officer, Ward-7(1), Hyderabad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1189/HYD/2025[2020-21]Status: DisposedITAT Hyderabad19 Dec 2025AY 2020-21

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1189/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2020-21) Shri Kaithi Govardhan Vs. Income Tax Officer Reddy ( Huf ) Ward 7 (1) Hyderabad Hyderabad Pan:Aahhk3441C (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Snsr Chinmai, Advocate राज" व "ारा/Revenue By:: Shri T. Venkanna, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 15/12/2025 घोषणा की तारीख/Pronouncement: 19/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri SNSR Chinmai, AdvocateFor Respondent: : Shri T. Venkanna, Sr. DR

restore the matter to the file of the Ld. AO to decide the issue afresh in accordance with law after providing adequate opportunity of being heard to the assessee. The assessee shall be at liberty to file all relevant evidence/material in support of its claim. The assessee is directed

Krishnakumar Manda, Medchal vs. DCIT., Circle-12(1), Hyderabad

ITA 1017/HYD/2025[2021-22]Status: DisposedITAT Hyderabad19 Dec 2025AY 2021-22

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos. 1016 & 1017/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2021-22) Shri Krishnakumar Manda, Vs. Deputy Commissioner Of Medchal Income Tax Pan:Bmspm9739D Circle 12(1) Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Phaneendra Nag, Ca राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 11/12/2025 घोषणा की तारीख/Pronouncement: 19/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri Phaneendra Nag, CAFor Respondent: : Shri S. Arun Kumar, Sr. DR
Section 144BSection 2Section 250Section 69

extent the order is prejudicial to the interest of the appellant. 2. The Ld. CIT(A) erred by not giving reasonable opportunity of being heard. 3. The Ld. CIT(A) ought to appreciate the fact that Ld.AO has erred in not following the clauses (xi), (xvi) & (xviii) of Sub section ... complete disregard to the Statutory Provision. 4. The Ld. CIT(A) ought to appreciate the fact that Ld.AO erred in not giving proper opportunity of being heard to the appellant in submitting the sources of cash deposits made during the AY 2021-22. 5. The Ld. CIT(A) ought

Krishnakumar Manda, Medchal vs. DCIT., Circle-12(1), Hyderabad

ITA 1016/HYD/2025[2021-22]Status: DisposedITAT Hyderabad19 Dec 2025AY 2021-22

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos. 1016 & 1017/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2021-22) Shri Krishnakumar Manda, Vs. Deputy Commissioner Of Medchal Income Tax Pan:Bmspm9739D Circle 12(1) Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Phaneendra Nag, Ca राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 11/12/2025 घोषणा की तारीख/Pronouncement: 19/12/2025 आदेश/Order Per Madhusudan Sawdia, A.M.:

For Appellant: Shri Phaneendra Nag, CAFor Respondent: : Shri S. Arun Kumar, Sr. DR
Section 144BSection 2Section 250Section 69

extent the order is prejudicial to the interest of the appellant. 2. The Ld. CIT(A) erred by not giving reasonable opportunity of being heard. 3. The Ld. CIT(A) ought to appreciate the fact that Ld.AO has erred in not following the clauses (xi), (xvi) & (xviii) of Sub section ... complete disregard to the Statutory Provision. 4. The Ld. CIT(A) ought to appreciate the fact that Ld.AO erred in not giving proper opportunity of being heard to the appellant in submitting the sources of cash deposits made during the AY 2021-22. 5. The Ld. CIT(A) ought

Shakti Hormann Private Limited, Hyderabad vs. DCIT, Circle-3(1), Hyderabad

ITA 917/HYD/2024[2020-21]Status: DisposedITAT Hyderabad19 Dec 2025AY 2020-21

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.917/Hyd/2024 (निर्धारण वर्ष/Assessment Year:2020-21) Shakti Hormann Private Limited, Hyderabad. Vs. Dcit, Circle-3(1), Hyderabad. Pan: Aadcs4024Q (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri P. Murali Mohan Rao, Ca राजस्व द्वारा / Revenue By: Ms. U. Mini Chandran, Cit-Dr सुनवाई की तारीख /Date Of Hearing: 15/10/2025 घोषणा की तारीख / Date Of 19/12/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Company Is Directed Against The Final Assessment Order Passed By The Assessing Officer (For Short, “A.O.”) Under Section 143(3) R.W.S 144C(13) R.W.S 144B Of The Income Tax Act, 1961 (For Short, “The Act”) Dated 25/07/2024 For The

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Ms. U. Mini Chandran
Section 143(3)Section 144CSection 153Section 92C

requires verification of any issue by way of submission of any document by the assessee or any other person or where an opportunity of being heard is to be provided to the assessee, the order giving effect to the said order under section 250 or section 254 or section ... section (5), in conformity with the directions complete, notwithstanding anything to the contrary contained in section 153, the assessment without providing any further opportunity of being heard to the assessee, within one month from the end of the month in which such direction is received. What is contemplated under section