“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

Unnat Bharat Social Welfare Society, Shakarpur vs. CIT(Exemption), Delhi

In the result, assessee’s appeals ITA Nos

ITA 4140/DEL/2025[2024-25]Status: DisposedITAT Delhi08 Dec 2025AY 2024-25

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Roy

Section 12ASection 12A(1)(ac)Section 13(1)(c)Section 2(15)Section 80GSection 80G(5)

these appeals are disposed of by remitting the matter back to the file of Ld. CIT(E) for fresh adjudication by granting an opportunity of being heard to the assessee and upon considering the evidence on record or evidences as per requirement of the authorities below and any other evidence

Xion Progressive Educational Society, Gurgaon vs. Exemptions Ward Faridabad, Faridabad

In the result, assessee’s appeal is allowed for statistical purposes

ITA 4137/DEL/2025[2017-18]Status: DisposedITAT Delhi08 Dec 2025AY 2017-18

Bench: Shri S. Rifaur Rahman & Ms. Madhumita Royassessment Year: 2017-18

Section 143(3)

this appeal is disposed of by remitting the matter back to the file of Ld. CIT(A) for fresh adjudication by granting an opportunity of being heard to the assessee and upon considering the evidence on record or any other evidence which the assessee may choose to file

To Cum Pdo Panchkula, Panchkula vs. ITO TDS, Karna

In the result, appeal of the assessee in ITA No

ITA 3338/DEL/2025[2015-16]Status: DisposedITAT Delhi08 Dec 2025AY 2015-16

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Ms. Ankush Kalra, Sr. DR

Section 133ASection 201Section 201(1)

reflecting the A.Y as 2015-16, although the appeal was filed for the assessment year 2016-17. The CIT(A), without affording proper opportunity of being heard to the assessee, disregarded the issuance of incorrect notices reflecting the wrong assessment year. This oversight was neither acknowledged nor rectified and stands

Jws Multi State Co-Operative Housing Society Limited, Delhi vs. ITO Ward 60(5), Delhi

In the result, appeal of the assessee in ITA No

ITA 3260/DEL/2025[2016-17]Status: DisposedITAT Delhi08 Dec 2025AY 2016-17

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Sanjay Joshi, CAFor Respondent: Ms. Ankush Kalra, Sr. DR

very outset, the ld. counsel for the assessee submitted that the ld. CIT(A) has decided the issues without providing adequate opportunity of being heard to the assessee to present its case. It is the say of the ld. counsel for the assessee that several additional evidences have been submitted ... operative Housing Society Vs. ACIT of the Assessing Officer to examine the additional evidence and decide the issues afresh after allowing adequate opportunity of being heard to the assessee. 6. The assessee is also directed to provide necessary information /documents as required by the authorities and co-operate in adjudication

Holy Consultancy Services Pvt. Ltd., Delhi vs. ITO, Ward-11(2), New Delhi

In the result, this appeal is allowed for statistical purpose

ITA 3061/DEL/2024[2014-15]Status: DisposedITAT Delhi08 Dec 2025AY 2014-15

Bench: Shrimahavir Singh, Hon’Ble & Shrisanjay Awasthiआ.अ.सं/.I.T.A No.3061/Del/2024 िनधा"रणवष"/Assessment Year:2014-15 बना Holy Consultancy Services Pvt. Ltd., Ito, म Flat No.10, C 1/2 Model Town, Delhi. C.R. Building, Pan No.Aaach0229H Vs. I.P. Estate, New Delhi. अपीलाथ" Appellant ""यथ"/Respondent

Section 250Section 68

remand this matter back to the file of the Ld. AO for fresh assessment. Needless to say, the Ld. AO would give ample opportunity of being heard to the assessee. 4. In the result, this appeal is allowed for statistical purpose. Order pronounced in the open court on 08.12.2025 (MAHAVIR

Swami Darshanand Institute of Management and Technology, Haridwar vs. ITO, W-1(3)(1), Haridwar

In the result, appeal of the assessee is allowed

ITA 129/DDN/2025[2015-16]Status: DisposedITAT Dehradun05 Dec 2025AY 2015-16

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalswami Darshanand Institute Of Income Tax Officer, Management & Technology, Ward-1(3)(1), Gurukul Mahavidyalaya, Vs. Haridwar. P.O. Gurukul Kangi, Jwalpur, Haridwar-249407. Pan:Aalas6789G (Appellant) (Respondent) Assessee By Shri Shalil Agarwal, Sr. Adv. & Shri Salies Gupta, Adv. & Shri Uma Shankar, Adv. Department By Shri Amar Pal Singh, Jcit-Dr Date Of Hearing 11.09.2025 Date Of Pronouncement 05.12.2025 O R D E R Per Manish Agarwal, Am: This Appeal Is Filed By The Assessee Against The Order Of Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (‘The Cit(A) In Short) Passed U/S 250 Of The Income Tax Act, 1961, Dated 19.05.2025 For Assessment Year 2015-16. 2. Brief Facts Of The Case Are That The Assessee Is A Society Engaged In Imparting Education. The Ao Based On The Information That Assessee Has Deposited Cash Of Rs.93,10,000/- In The Saving Bank Account Maintained With A Central Bank Of India Which Is Not Declared & Thus Case Was Reopened By Issue Of Notice U/S 148 Of The Act. Thereafter, Submissions Were Made By The Assessee Wherein It Is Claimed That This Account Pertained To Other Society & All The Deposits Are Duly

Section 144BSection 147Section 148Section 148ASection 250Section 69A

Appeals) has erred in law and on facts in sustaining additions in the hands of assessee appellant, without giving any fair and proper opportunity of being heard to the appellant and further, erred in sustaining the aforesaid addition purely on assumptions, presumptions, surmises and conjectures and hence, the addition

Pagadala Velugonda Reddy, Durg vs. ACIT-1(1), Bhilai

In the result, the appeal is dismissed

ITA 726/RPR/2025[2013-14]Status: HeardITAT Raipur05 Dec 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.726/Rpr/2025 "नधा"रण वष" /Assessment Year : 2013-14 Pagadala Velugonda Reddy Lig 284, Hudco, Bhilai-490 009 (C.G.) Pan: Abmpv7318K

For Appellant: Shri Yash Jain, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 147Section 271(1)(b)Section 271FSection 69

aside, with directions to revisit the matter and adjudicate denovo. 10. Needless to say, the assessee shall be afforded with reasonable opportunity of being heard in the set aside appellate proceedings, wherein the assessee shall cooperate and assist proactively, failing which the Ld. CIT (A) would be at liberty

M/S. Orissa Industries Limited, Cuttack vs. Income Tax Officer, Ward-2(2), Cuttack

In the result, appeal of the assessee stands partly allowed for statistical purpsoes

ITA 561/CTK/2025[2012-13]Status: DisposedITAT Cuttack05 Dec 2025AY 2012-13

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.561/Ctk/2025 ("नधा"रण वष" / Assessment Year : 2012-13) Orissa Industries Limited, Barang, Vs Income Tax Officer, Ward-2(2), Cuttack Cuttack Pan No. : Aaaco2103K (अपीलाथ" /Appellant) (""यथ" / Respondent) .. "नधा"रती क" ओर से /Assessee By : Shri Rasmirannjan Patnaik, Ar राज"व क" ओर से /Revenue By : Shri Vijay Singh, Ld Sr Dr सुनवाई क" तार"ख / Date Of Hearing : 5/12/2025 घोषणा क" तार"ख/Date Of Pronouncement : 5/12/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Dated 22.08.2025 Passed By Ld Cit(A), Nfac, Delhi In Appeal No.Cit(A), Bhubaneswar- 2/10364/2019-20 For The Assessment Year 2012-13. 2. Shri Rashhmiranjan Patnaik Ld Ar Appeared For The Assessee & Shri Vijaya Singh, Ld Sr Dr Appeared For The Revenue. 3. It Was Submitted By The Ld Ar That The Ld Cit(A) Has Passed Exparte Order Without Hearing To The Assessee. He Submitted That Even If The Assessment Order Has Been Passed U/S.147 Of The Act. He Submitted That If One More Opportunity Is Granted, The Assessee Will Cooperate In The Set Aside Proceedings

For Appellant: Shri Rasmirannjan Patnaik, ARFor Respondent: Shri Vijay Singh, ld Sr DR

Section 147

justice, the issue in this appeal are restored to the file of the ld CIT(A) for fresh adjudication after affording reasonable opportunity of being heard to the assessee. The assessee is directed to comply with the notices issued by the ld CIT(A) and furnish all the required evidences

Biju Patnaik University of Technology, Rourkela vs. Deputy Commissioner of Income Tax, Circle-2(1), Bhubaneswar

In the result, all the four appeals of the assessee are partly allowed for statistical purposes

ITA 558/CTK/2025[2018-19]Status: DisposedITAT Cuttack05 Dec 2025AY 2018-19

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAJESH KUMAR (Accountant Member)

For Appellant: Shri Digant Das, ARFor Respondent: Shri Vijay Singh, Sr. DR

justice, we restore the issues in these appeals to the file of ld. AO for adjudicating afresh after providing the assessee adequate opportunity of being heard. However, looking to the non- cooperation of the assessee during the course of appellate proceedings even after issuance of notices to the assessee

Rebati Dandapat, Mandir Pada, Nuapada, Odhisa vs. Income Tax Officer, Bhawani Patna Warda, Bhawanipatna

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

ITA 554/CTK/2025[2020-21]Status: DisposedITAT Cuttack05 Dec 2025AY 2020-21

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.554/Ctk/2025 ("नधा"रण वष" / Assessment Year : 2020-2021) Rebati Dandapat Vs Ito, Bhawanipatna Ward, W/O:- Priyaranjan Dandapat, Bhawanipatna Ward No:- 04, Mandir Pada, Nuapada, 766105 Pan No. : Dqrpd 6219 L (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri Vijay Gupta, Ar राज"व क" ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 05/12/2025 घोषणा क" तार"ख/Date Of Pronouncement : 05/12/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of Ld.Cit(A), National Faceless Appeal Centre(Nfac), Delhi Dated 24/04/2025 For The Assessment Year 2020-2021. 2. The Appeal Of The Assessee Is Delayed By 106 Days. In This Regard, The Assessee Has Filed An Application For Condonation Of Delay Supported With An Affidavit Stating Therein Sufficient Reasons For Delay In Filing The Appeal Before The Tribunal, Which Are Not Found To Be False. Ld. Sr. Dr Did Not Object To Condone The Delay. Accordingly, We Condone The Delay Of 106

For Appellant: Shri Vijay Gupta, ARFor Respondent: Shri Vijay Singh, Sr. DR

justice, we restore the issues in the appeal to the file of ld. CIT(A) for adjudicating afresh after providing the assessee adequate opportunity of being heard. However, looking to the non-cooperation of the assessee during the course of appellate proceedings even after issuance of notices to the assessee

Mr. Polavarapu Sambasiva Rao, Bhubaneswar vs. Deputy Commissioner of Income Tax, Circle-1(1), Bhubanewar

In the result, all the three appeals of the assessee are partly allowed for statistical purposes

ITA 550/CTK/2025[2018-19]Status: DisposedITAT Cuttack05 Dec 2025AY 2018-19

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAJESH KUMAR (Accountant Member)

For Appellant: Shri Basudev Panda, Senior AdvocateFor Respondent: Shri Vijay Singh, Sr. DR

Mr. Polavarapu Sambasiva Rao, Bhubaneswar vs. Deputy Commissioner of Income Tax, Circle-1(1), Bhubaneswar

In the result, all the three appeals of the assessee are partly allowed for statistical purposes

ITA 549/CTK/2025[2017-18]Status: DisposedITAT Cuttack05 Dec 2025AY 2017-18

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAJESH KUMAR (Accountant Member)

For Appellant: Shri Basudev Panda, Senior AdvocateFor Respondent: Shri Vijay Singh, Sr. DR

Mr.Polavarapur Sambasiva Rao, Bhubaneswar vs. Deputy Commissioner of Income Tax, Circle-1(1), Bhubaneswar

In the result, all the three appeals of the assessee are partly allowed for statistical purposes

ITA 548/CTK/2025[2016-17]Status: DisposedITAT Cuttack05 Dec 2025AY 2016-17

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAJESH KUMAR (Accountant Member)

For Appellant: Shri Basudev Panda, Senior AdvocateFor Respondent: Shri Vijay Singh, Sr. DR

Mrs. Jayanti Mohapatra, Bhubaneswar vs. Income Tax Officer, Bhadrak Ward, Bhaderak

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

ITA 539/CTK/2025[2015-16]Status: DisposedITAT Cuttack05 Dec 2025AY 2015-16

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.539/Ctk/2025 (नििाारण वर्ा / Assessment Year : 2015-2016) Mrs. Jayanti Mahapatra Vs Ito Ward Bhadrak Qtr.No.4 Type-Ii, C/O J.K.Mohanty, Survey Of India Colony, Jayadev Vihar, Bhubaneswar-751013 Pan No. : Aoepm 2327 Q (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Basudev Panda, Senior Advocate & Shri B.R.Panda, Advocate राजस्व की ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 05/12/2025 घोषणा की तारीख/Date Of Pronouncement : 05/12/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld.Cit(A), National Faceless Appeal Centre(Nfac), Delhi, Dated 08.12.2023 For The Assessment Year 2015-2016. 2. The Appeal Of The Assessee Is Delayed By 586 Days. In This Regard, The Assessee Has Filed Condonation Application Along With Affidavit For Condonation Of Delay Stating Therein Sufficient Reasons, Which Are Not Found To Be False. Accordingly, The Delay Of 586 Days In The Appeal Of The Assessee Is Condoned & The Appeal Is Admitted For Hearing.

For Appellant: Shri Basudev Panda, Senior Advocate &For Respondent: Shri Vijay Singh, Sr. DR

justice, we restore the issues in this appeal to the file of ld. AO for adjudicating afresh after providing the assessee adequate opportunity of being heard. However, looking to the non- cooperation of the assessee during the course of appellate proceedings even after issuance of notices to the assessee

Safal Construction Private Limited, Bhubaneswar vs. Deputy Commissioner of Income Tax, Bhubnaeswar

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

ITA 533/CTK/2025[2016-17]Status: DisposedITAT Cuttack05 Dec 2025AY 2016-17

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAJESH KUMAR (Accountant Member)

For Appellant: Shri C.Parida, ARFor Respondent: Shri Vijay Singh, Sr. DR

justice, the issues in this appeal are restored to the file of the ld.AO for readjudication afresh after granting the assessee adequate opportunity of being heard, subject to a payment of cost of Rs.10,000/-(Rupees Ten Thousand only) payable by the assesee to the Income Tax Appellate Tribunal

Brm Hi Tech Steels Private Limited, Bhubaneswar vs. Income Tax Officer, Ward-1, Rourkela

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

ITA 528/CTK/2025[2014-15]Status: DisposedITAT Cuttack05 Dec 2025AY 2014-15

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.528/Ctk/2025 ("नधा"रण वष" / Assessment Year : 2014-2015) Brm Hi Tech Steels Private Vs Ito, Ward-1, Rourkela Limited Village:-Mahul Palli, Hotel Deluxe Lane:- Rourkela, Sundargarh, 769001 Pan No. : Aadcb 1433 A (अपीलाथ" /Appellant) (""यथ" / Respondent) .. "नधा"रती क" ओर से /Assessee By : Shri D. Parida, Ar राज"व क" ओर से /Revenue By : Shri Vijay Singh, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing : 05/12/2025 घोषणा क" तार"ख/Date Of Pronouncement : 05/12/2025

For Appellant: Shri D. Parida, ARFor Respondent: Shri Vijay Singh, Sr. DR

issues in this appeal are restored to the file of ld.AO for adjudicating afresh after providing the assessee adequate opportunity of being heard. The assessee is directed to cooperate before the ld. AO in the set aside proceedings. 5. In the result, appeal of the assessee is partly allowed

Biju Patnaik University of Technology, Rourkela vs. Deputy Commissioner of Income Tax, Circle-2(1), Bhubaneswar

In the result, all the four appeals of the assessee are partly allowed for statistical purposes

ITA 505/CTK/2025[2018-19]Status: DisposedITAT Cuttack05 Dec 2025AY 2018-19

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAJESH KUMAR (Accountant Member)

For Appellant: Shri Digant Das, ARFor Respondent: Shri Vijay Singh, Sr. DR

Biju Patnaik University of Technology, Rourkela vs. Income Tax Officer, National Faceless Assessment Unit

In the result, all the four appeals of the assessee are partly allowed for statistical purposes

ITA 489/CTK/2025[2019-20]Status: DisposedITAT Cuttack05 Dec 2025AY 2019-20

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAJESH KUMAR (Accountant Member)

For Appellant: Shri Digant Das, ARFor Respondent: Shri Vijay Singh, Sr. DR

Biju Patnaik University of Technology, Bput Colony, Chhend vs. Income Tax Officer, the National Faceless Assessment Centre

In the result, all the four appeals of the assessee are partly allowed for statistical purposes

ITA 488/CTK/2025[2016-17]Status: DisposedITAT Cuttack05 Dec 2025AY 2016-17

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAJESH KUMAR (Accountant Member)

For Appellant: Shri Digant Das, ARFor Respondent: Shri Vijay Singh, Sr. DR

Sangrami Voluntary Organisation, Balasore vs. The Income Tax Officer(Exemption), Cuttack

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

ITA 485/CTK/2025[2020-21]Status: DisposedITAT Cuttack05 Dec 2025AY 2020-21

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अपील सं/Ita No.485/Ctk/2025 ("नधा"रण वष" / Assessment Year : 2020-2021) Sangrami Voluntary Vs Ito(Exemption), Cuttack Organisation, At: Chafla, Po – Kanaki, Hatigarh, Dist : Balasore-756033 Pan No. : Aabas 9558 H (अपीलाथ" /Appellant) .. (""यथ" / Respondent) "नधा"रती क" ओर से /Assessee By : Shri P.K.Mishra, Ar राज"व क" ओर से /Revenue By : Shri Ashik Kumar Chakraborty, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 05/12/2025 घोषणा क" तार"ख/Date Of Pronouncement : 05/12/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of Ld.Cit(A), National Faceless Appeal Centre(Nfac), Delhi Dated 14.07.2025 For The Assessment Year 2020-2021. 2. It Was Submitted By The Ld.Ar That The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee Ex-Pate. It Was The Prayer That The Matter May Be Restored To The File Of The Ld. Ao To Decide The Issue Involved In The Appeal Afresh So That The Assessee Could Be Able To Produce All The Evidence To Substantiate Its Claim.

For Appellant: Shri P.K.Mishra, ARFor Respondent: Shri Ashik Kumar Chakraborty, CIT-DR

justice, we restore the issues in the appeal to the file of ld. AO for adjudicating afresh after providing the assessee adequate opportunity of being heard. 5. In the result, appeal of the assessee is partly allowed for statistical purposes. Order dictated and pronounced in the open court on /12/2025