“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

Meenaxi Gems Pvt Ltd, Surat vs. Income Tax Officer, WD-1(1)(4), Surat

In the result, the appeal of the assessee in ITA No

ITA 613/SRT/2025[2007-08]Status: DisposedITAT Surat27 Nov 2025AY 2007-08

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.612 & 613/Srt/2025 Assessment Year: (2007-08) (Hybrid Hearing) Meenaxi Gems Pvt. Ltd., Vs. Ito, 5/1108-A, 1167/68-B, Santok Ward – 1(1)(4), Diamonds Office No.106, Gurjar Surat Faliya, Haripura, Surat - 395003 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aadcm4645B (Appellant) (Respondent) Appellant By Shri Prakash Jhunjhunwala, Ar Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 15/09/2025 Date Of Pronouncement 27/11/2025

Section 145(3)Section 147Section 148Section 151(1)Section 250Section 271(1)(c)Section 274

account of bogus purchase. Besides, the AO initiated penalty proceedings u/s.271(1)(c) of the Act. Subsequently, after providing reasonable opportunity of being heard to the assessee, the AO passed the penalty order on 25.03.2019, ITA Nos.612 & 613/SRT/2025/AY 2007-08 Meenaxi Gems Pvt. Ltd. imposing a penalty of Rs.11

Meenaxi Gems Pvt Ltd, Surat vs. Income Tax Officer, WD-1(1)(4), Surat

In the result, the appeal of the assessee in ITA No

ITA 612/SRT/2025[2007-08]Status: DisposedITAT Surat27 Nov 2025AY 2007-08

Section 145(3)Section 147Section 148Section 151(1)Section 250Section 271(1)(c)Section 274

Rajinder Kumar, Allahabad Road, Faizabad vs. Income Tax Officer, Faizabad

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

ITA 293/LKW/2025[2018-2019]Status: DisposedITAT Lucknow27 Nov 2025AY 2018-2019

Bench: Shri Kul Bharatआयकर अपील सं/ Ita No.293/Lkw/2025 ननिाारण वर्ा/ Assessment Year: 2018-19 Rajinder Kumar V. Income Tax Officer Mahavir Agricultural Industries, Income Tax Department, Allahabad Road, Faizabad- Faizabad, Uttar Pradesh- 224001. 224001. Pan:Aawpk2983L अपीलार्थी/(Appellant) प्रत्यर्थी/(Respondent) अपीलार्थी कक और से/Appellant By: Shri Sudhir Sehgal, Advocate प्रत्यर्थी कक और से /Respondent By: Shri Amit Kumar, Sr. Dr सुनवाई कक तारीख / Date Of Hearing: 25 11 2025 घोर्णा कक तारीख/ Date Of 27 11 2025 Pronouncement: O R D E R Per Kul Bharat.: This Appeal, By The Assessee, Is Directed Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac) Dated 17.02.2025 Pertaining To The Assessment Year 2018-19. The Assessee Has Raised The Following Grounds Of Appeal: - “1. That The Order Of The Ld. Cit(A) Is Against Law & Facts Of The Case On The File. 2. That The Ld. Cit(A) Erred In Sustaining The Addition Of Rs. 10,58,720/- Made By The Ao Under Section 69C Of Income Tax Act In Respect Of Purchases Made By The Assessee From M/S. Mideast Integrated Steel Ltd. 3. That The Ld. Cit(A) Gravely Erred In Not Allowing Proper Opportunity Of Being Heard. 4. That The Ld. Cit(A) Erred In Sustaining The Assessment Wrongly Reopened Under Section 147 Of The Income Tax Act, 1961 By The Ao. Page 2 Of 4 5. That The Appellant Begs To Add Or Amend Any Ground Of Appeal Before The Appeal Is Heard & Disposed Off.” 2. Apropos To The Grounds Of Appeal, The Ld. Counsel For The Assessee, At The Outset, Contended That The Impugned Order Has Been Passed Without Giving Effective Opportunity Of Being Heard To The Assessee. He, Therefore, Prayed That The Matter May Be Restored To The File Of The Ld. Cit(A) For Fresh Adjudication.

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Amit Kumar, Sr. DR

Section 147Section 69C

purchases made by the assessee from M/s. Mideast Integrated Steel Ltd. 3. That the Ld. CIT(A) gravely erred in not allowing proper opportunity of being heard. 4. That the Ld. CIT(A) erred in sustaining the assessment wrongly reopened under Section 147 of the Income ... grounds of appeal, the Ld. Counsel for the assessee, at the outset, contended that the impugned order has been passed without giving effective opportunity of being heard to the assessee. He, therefore, prayed that the matter may be restored to the file of the Ld. CIT(A) for fresh adjudication

Aavishkar Impex Pvt. Ltd., Ahmedabad vs. The Dy.CIT, Circle-1(1)(1), Ahmedabad

ITA 1589/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad27 Nov 2025AY 2022-23

Bench: Dr. B.R.R. Kumar, Vice- & Shri Siddhartha Nautiyal

For Appellant: Shri Aseem Thakkar, ARFor Respondent: Shri R P Rastogi, CIT.DR

Section 145(3)

Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre. (NFAC), Delhi has erred in passing an Ex-Parte order without providing reasonable opportunity of being heard to the appellant. Hence the same being against the principles of natural justice and equity requires to be quashed. 2. The Learned Commissioner

Aavishkar Impex Pvt. Ltd., Ahmedabad vs. The Dy.CIT, Circle-1(1)(1), Ahmedabad

ITA 1579/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad27 Nov 2025AY 2020-21

Bench: Dr. B.R.R. Kumar, Vice- & Shri Siddhartha Nautiyal

For Appellant: Shri Aseem Thakkar, ARFor Respondent: Shri R P Rastogi, CIT.DR

Section 145(3)

Aavishkar Impex Pvt. Ltd., Ahmedabad vs. The Dy.CIT, Circle-1(1)(1), Ahmedabad

ITA 1578/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad27 Nov 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice- & Shri Siddhartha Nautiyal

For Appellant: Shri Aseem Thakkar, ARFor Respondent: Shri R P Rastogi, CIT.DR

Section 145(3)

Dattatray Mahadev Tupe, Pune vs. ITO Ward 14(2) Pune, Pune

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

ITA 808/PUN/2025[2012-13]Status: DisposedITAT Pune27 Nov 2025AY 2012-13

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2012-13 Dattatray Mahadev Tupe Ito, Ward-14(2), Pune Flat No.506, Aspire Tower B 12, Vs. Amanora City, Hadapsar, Pune – 411028 Pan: Adypt5448E (Appellant) (Respondent) Assessee By : Shri D R Barve Department By : Shri A D Kulkarni Date Of Hearing : 27-11-2025 Date Of Pronouncement : 27-11-2025 O R D E R Per R.K. Panda, Vp:

For Appellant: Shri D R BarveFor Respondent: Shri A D Kulkarni

Section 142(1)Section 147Section 148

NFAC with a direction to grant one final opportunity to the assessee and decide the issue in accordance with 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

Om Marshal Art and Social Service Association, Daund vs. CIT Exemption, Pune

In the result, the appeal of the assessee is dismissed

ITA 2861/PUN/2024[- Na -]Status: DisposedITAT Pune27 Nov 2025

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

For Appellant: N O N EFor Respondent: Shri Amol Khairnar

Section 80GSection 80G(5)

directly relevant to the present proceedings. 3 However, the assessee has failed to comply despite giving sufficient opportunities as discussed above, including an opportunity of being heard. 6. Thus, the assessee has failed to furnish the details called for under the provisions of sub-clause (a) of clause

Committee Khuddamin Darghjat Hadde Kalan Khultabad, Aurangabad vs. CIT Exemption, Pune

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

ITA 2859/PUN/2024[- NA -]Status: DisposedITAT Pune27 Nov 2025

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

For Appellant: Shri Vijay More (Through Virtual)For Respondent: Shri Amol Khairnar

Section 12ASection 12A(1)(ac)

directly relevant to the present proceedings. However, the assessee has failed to comply despite giving sufficient opportunities as discussed above including an opportunity of being heard. 6. Thus, the assessee has failed to furnish the details called for under the provisions of section 12AB(1)(b)(i) of the Income ... aside to the file of the Ld. CIT(E) to adjudicate the same afresh on merits after affording a reasonable opportunity of being heard to the assessee. 6. The Ld. DR had no objection the above request of the Ld. AR. 7. We have heard the Ld. Representatives

The Jain Kasar Samaj Sanstha, Sangli, Maharashtra vs. The CIT (Exemption), Pune, Maharashtra

In the result, the appeal filed by the Assessee is devoid of merits and the

ITA 2613/PUN/2024[2024-2025]Status: DisposedITAT Pune27 Nov 2025AY 2024-2025

For Appellant: N O N EFor Respondent: Shri Udaya Bhaskar Jakke

Section 12ASection 12A(1)(ac)Section 80G

otherwise of any specified violation, (ii) pass an order in writing, cancelling the registration of such trust or institution, after affording a reasonable opportunity of being heard, for such previous year and all subsequent previous years, if he is satisfied that one or more specified violations have taken place

The Jain Kasar Samaj Sanstha, Sangli, Maharashtra vs. The CIT (Exemption), Pune, Maharashtra

In the result, the appeal filed by the Assessee is devoid of merits and the

ITA 2612/PUN/2024[2024-2025]Status: DisposedITAT Pune27 Nov 2025AY 2024-2025

For Appellant: ΝΟΝΕFor Respondent: Shri Udaya Bhaskar Jakke

Section 12ASection 12A(1)(ac)Section 80G

Bhuvaneswari Lines and Logistics Pvt. Ltd., Chennai vs. ITO, Ncw-1(1), Chennai

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

ITA 2438/CHNY/2025[2018-19]Status: DisposedITAT Chennai27 Nov 2025AY 2018-19

Bench: Shri Ss Viswanethra Ravi & Shri Jagadishआयकर अपील सं./Ita No.2438/Chny/2025 िनधा9रण वष9 /Assessment Year: 2018-19

For Appellant: Shri G. Tarun, AdvocateFor Respondent: Ms. M. Subashri, Addl. CIT(virtual)

Section 143(3)

submitted that both the A.O. as well as the Ld. CIT(A) had passed their respective orders ex-parte without providing proper opportunity of being heard. Therefore, in the interest of justice, it was prayed that one more opportunity may be granted to the assessee to substantiate its case ... impugned order and remit the matter back to the file of the A.O for denovo assessment in accordance with law, after affording reasonable opportunity of being heard to the assessee. The assessee is also directed to comply with all the notices issued by the A.O and furnish all relevant details

Lalit Kumar Mohanlal Jain, Mumbai vs. ITO Ward 20(2)(1), Mumbai

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

ITA 6129/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Nov 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Ms. Ridhisha Jain (virtually appeared)For Respondent: Shri Surendra Mohan (SR DR)

Section 10(38)Section 139(1)Section 143(3)Section 147Section 148Section 250Section 272A(1)(d)

novo adjudication. We to prejudice the appellate proceedings. Needless to say, the Ld. CIT(A) shall grant the assessee a reasonable opportunity of being heard before passing a fresh order. The assessee, in turn, shall extend full cooperation and diligently participate in the set-aside proceedings. 6. In the result ... novo adjudication. The Ld. CIT(A) shall consider the merits of the case afresh and pass a speaking order after affording adequate opportunity of being heard to the assessee. 10. In the result, the appeal of the assessee is allowed for statistical purpose. 11. As a result, all the appeals

Lalita Bharatkumar Jain, Mumbai vs. DCIT Circle 20(1), Mumbai

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

ITA 6078/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Nov 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Ms. Ridhisha Jain (virtually appeared)For Respondent: Shri Surendra Mohan (SR DR)

Section 10(38)Section 139(1)Section 143(3)Section 147Section 148Section 250Section 272A(1)(d)

Lalita Bharatkumar Jain, Mumbai vs. DCIT Circle 20(1), Mumbai

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

ITA 6077/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Nov 2025AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Ms. Ridhisha Jain (virtually appeared)For Respondent: Shri Surendra Mohan (SR DR)

Section 10(38)Section 139(1)Section 143(3)Section 147Section 148Section 250Section 272A(1)(d)

Nolash Joseph Julio Felix Noronha, Mumbai vs. Income Tax Officer-Ward 25(3)(1), Mumbai

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

ITA 6075/MUM/2025[2018-19]Status: DisposedITAT Mumbai27 Nov 2025AY 2018-19

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailnolash Joseph Julio Felix Noronha, United Family Welfare, Trust Building 297 A, Bellasis Road, Mumbai Central, Mumbai – 400008 ............... Appellant Pan : Adzpn0769M V/S Income Tax Officer, Ward – 25(3)(1)., ……………… Respondent Kautilya Bhavan, Bkc, Mumbai

For Appellant: Shri Prateek JainFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR

Section 250Section 90

erred in confirming the action of Id.AO in passing order under section 250 of the Act without affording effective opportunity of being heard. 2 2. On the facts and circumstances of the appellant's case and in law, the Id. CIT(A) erred in confirming the action of Id.AO

Buddhadev Educational Charitable Trust, Thane vs. Exemption Ward, Thane

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

ITA 5889/MUM/2025[2025-26]Status: DisposedITAT Mumbai27 Nov 2025AY 2025-26

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2025-26 Buddhadev Educational Vs Income Tax Officer (Exemption), Charitable Trust Ward, Thane A/8 Buddhadev Nagar Sarovar Qureshi Mansion, Gokhale Road, Malyan, Dahanu Road, Thane Naupada, Thane West, Thane 401601 400602 Pan: (Aabtb8363Q) Appellant Respondent Present For: Appellant By : Shri Piyush Bafna, Ca (Virtually Appeared) Respondent By : Ms. Agnes Thomas, Cit Dr Date Of Hearing : 20.11.2025 Date Of Pronouncement : 27.11.2025 O R D E R Per Girish Agrawal: This Appeal Filed By The Assessee Is Against The Order Of Cit(Exemption), Pune Vide Din & Notice No. Itba/Exm/F/Exm45/2025- 26/1079838444(1) Dated 21.08.2025 Passed U/S. 12Ab Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”), Dated 21.08.2025. 2. Grounds Taken By The Assessee Are Reproduced As Under: “Erroneous Rejection Of Application: 1. On The Facts & In The Circumstances Of The Case & On Facts Hon'Ble Cit Exemption Pune Has Erred In Rejecting The Application Of The Appellant Trust For Final

For Appellant: Shri Piyush Bafna, CA (Virtually appeared)For Respondent: Ms. Agnes Thomas, CIT DR

Section 12ASection 12A(1)(ac)

while processing the application made by the assessee for the purpose of granting final registration. Needless to say that, assessee be given reasonable opportunity of being heard and make any further submission, if so required. Accordingly, grounds raised by the assessee in this respect are allowed for the statistical purposes

Stella D Souza, Mumbai vs. ITO Ward 31(2)(1), Mumbai

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

ITA 5719/MUM/2025[2013-14]Status: DisposedITAT Mumbai27 Nov 2025AY 2013-14

Bench: Shri Narender Kumar Choudhryassessment Year: 2013-14 Ms. Stella D Souza, Ito 31(2)(1), B/102 Diptigreen, Kautilya Bhavan Opp Bombay Cambridg School Vs. Bandra Kurla Complex, Chakala, Andheri (E), Bandra (E), Mumbai – 400 099 Mumbai - 400099 Pan: Acjpd4624Q (Appellant) (Respondent) Present For: Assessee By : Shri S.C. Agarwal, Ld. A.R. Revenue By : Shri Praveen K. Srivastav, Ld. Sr. D.R. Date Of Hearing : 17.11.2025 Date Of Pronouncement : 27.11.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 28.03.2025, Impugned Herein, Passed By The Ld. Commissioner Of Income Tax (Appeals) Addl/Jcit(A) (In Short Ld. Commissioner) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2013-14. 2. In This Case, The Assessee Being An Individual & Director In M/S. Silver Global Services Pvt. Ltd. Had Earned Interest Income Of Rs.6,48,842/- From Fixed Deposits With Model Co-Operative Bank Ltd. & In Order To Avoid Premature Encashment Of Fd Had Taken Loan Against Such Fd From Model Co-Operative Bank Ltd. & Paid Interest To The Said Bank To The Tune Of Rs.8,39,626/- & Since The Interest Paid Was More Than The Interest Received, Therefore, Has Not Shown Such Interest Earned.

For Appellant: Shri S.C. Agarwal, Ld. A.RFor Respondent: Shri Praveen K. Srivastav, Ld. Sr. D.R

Section 147Section 148Section 250

aforesaid facts as observed above and considering the judgment relied on by the Assessee. Suffice to say, the Ld. Commissioner shall grant reasonable opportunity of being heard to the Assessee. 9. In the result, the Assessee’s appeal is allowed for statistical purposes. Order pronounced in the open court

Savita Rameshchandra Mehta, Mumbai vs. Ward 41(1)(4), Mumbai

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

ITA 5705/MUM/2025[2011-12]Status: DisposedITAT Mumbai27 Nov 2025AY 2011-12

Bench: Shri Narender Kumar Choudhry, Jm Savita Rameshchandra Mehta Ward 41(1)(4), Mumbai Flat No. 18, Hit Niketan Co-Op. Hsg. Soc. Sps Road, Kokan Nagar, Vs. Bhandup West, Mumbai – 400078. Pan/Gir No. Aahpm3210B (Appellant) : (Respondent) Assessee By : Shri R. L. Rathi Respondent By : Shri Praveen K. Srivastav, Sr. Dr Date Of Hearing : 19.11.2025 Date Of Pronouncement : 27.11.2025 O R D E R Per Narender Kumar Choudhry, J M:

For Appellant: Shri R. L. RathiFor Respondent: Shri Praveen K. Srivastav, SR

Section 143(3)Section 250Section 69B

required. Thus, the case is remanded to the file of the Ld. Commissioner for decision afresh, suffice to say by affording reasonable opportunity of being heard to the assessee. The assessee is also directed to comply with the notices to be issued by the Ld. Commissioner and file the relevant

Viswanathan Vettri Vendhen, Mumbai vs. Deputy Commissioner of Income Tax Circle 42(3)(1), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 5652/MUM/2025[2019-20]Status: DisposedITAT Mumbai27 Nov 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry, Jm Viswanathan Vettri Dcit, Circle 42(3)(1), M 108, The Retreat By Mint Mumbai Homes, Senthil Nagar, Vs. Sowripalayam Road, Coimbatore – 641028. Pan/Gir No. Aclpv8496Q (Appellant) : (Respondent) Assessee By : None Respondent By : Shri Praveen K. Srivastav, Sr. Dr Date Of Hearing : 19.11.2025 Date Of Pronouncement : 27.11.2025 O R D E R Per Narender Kumar Choudhry, J M:

For Appellant: NoneFor Respondent: Shri Praveen K. Srivastav, SR

Section 147Section 250

Viswanathan Vettri final, by remanding the instant case to the file of Ld. Commissioner for decision afresh, suffice to say by affording reasonable opportunity of being heard to the assessee. 8. The assessee is also directed to comply with the notices to be issued by the Ld. Commissioner and file