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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

Ravinder Reddy Singidi, Vikarabad vs. ITO., Ward-1, Vikarabad

In the result, all the three appeals, i

ITA 1163/HYD/2025[2016-17]Status: DisposedITAT Hyderabad31 Oct 2025AY 2016-17

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 142(1)Section 147Section 148Section 250Section 69A

Reddy Singidi vs. ITO order. Needless to say, the CIT(A) in the course of the set aside proceedings shall afford a reasonable opportunity of being heard to the assessee. 15. Resultantly, the appeal filed by the assessee is allowed for statistical purposes in terms of our aforesaid observations

Ravinder Reddy Singidi, Vikarabad vs. ITO., Ward-1, Vikarabad

In the result, all the three appeals, i

ITA 1162/HYD/2025[2015-16]Status: DisposedITAT Hyderabad31 Oct 2025AY 2015-16

Bench: SHRI RAVISH SOOD, HON'BLE (Judicial Member), SHRI MADHUSUDAN SAWDIA HON'BLE (Accountant Member)

Section 142(1)Section 147Section 148Section 250Section 69A

Reddy Singidi vs. ITO order. Needless to say, the CIT(A) in the course of the set aside proceedings shall afford a reasonable opportunity of being heard to the assessee. 15. Resultantly, the appeal filed by the assessee is allowed for statistical purposes in terms of our aforesaid observations

Ravinder Reddy Singidi, Vikarabad vs. ITO., Ward-1, Vikarabad

In the result, all the three appeals, i

ITA 1161/HYD/2025[2014-15]Status: DisposedITAT Hyderabad31 Oct 2025AY 2014-15

Bench: making the additions to the appellant's income.

Section 142(1)Section 147Section 148Section 250Section 69A

Reddy Singidi vs. ITO order. Needless to say, the CIT(A) in the course of the set aside proceedings shall afford a reasonable opportunity of being heard to the assessee. 15. Resultantly, the appeal filed by the assessee is allowed for statistical purposes in terms of our aforesaid observations

Kapa Sindhu Mitra, Usa vs. Income Tax Officer (Int Taxn)-1, Hyderabad

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

ITA 513/HYD/2024[2016-17]Status: DisposedITAT Hyderabad31 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha Gआ.अपी.सं /Ita No.513/Hyd./2024 िनधा"रण वष"/Assessment Years 2016-2017 Kapa Sindhu Mitra, 20148, Holly Hock Terrace, The Income Tax Officer – Ash Burn, V A, Vs. [Int. Taxn)-1, Hyderabad – 500 004. United States Of America. Pan Azcpk8030D (Appellant) (Respondent) िनधा"रती "ारा/Assessee By : Sri Sashank Dundu, Advocate राज" व "ारा/Revenue By : Dr. Narendra Kumar Naik, Cit-Dr सुनवाई की तारीख/Date Of Hearing: 29.10.2025 घोषणा की तारीख/Pronouncement: 31.10.2025 आदेश/Order Per Vijay Pal Rao:

For Appellant: Sri Sashank Dundu, AdvocateFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 144C(5)Section 147Section 148Section 148ASection 149Section 151A

prescribed form and not providing another opportunity to file the same objections in the proper format thereby not providing a proper opportunity of being heard and violating the principles of Natural Justice. 8. The AO erred making an addition of Rs.25,00,000/-u/s 69A of the Act even though

The Bank Employees Co Operative Bank Ltd., Kolkata vs. DCIT, Cir-36, Kolkata

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

ITA 362/KOL/2025[2011-12]Status: DisposedITAT Kolkata31 Oct 2025AY 2011-12

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) & Shri Rajesh Kumari.T.A. No. 362/Kol/2025 Assessment Year: 2011-2012 The Bank Employees Cooperative Bank Limited,………………………………………………….Appellant 23A, Netaji Subhas Road, Kolkata-700001 [Pan:Aabat5298D] -Vs.- Deputy Commissioner Of Income Tax,..…….Respondent Circle-36, Kolkata, Aayakar Bhawan Poorva, 110, Shantipally, Kolkata-700107 Appearances By: Shri Sanbarta Koley, Fca, Appeared On Behalf Of The Assessee Ms. Archana Gupta, Addl. Cit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: August 07, 2025 Date Of Pronouncing The Order: October 31, 2025 O R D E R

Section 142(1)Section 143(1)Section 143(3)Section 271(1)(c)Section 36(1)(v)Section 40A(9)Section 83

support of its case. 5. That the penalty proceedings is a quasi-judicial proceeding and the Assessee must be given a reasonable opportunity of being heard for end of natural justice. 6. That the action of the learned Assessing Officer in proceeding with the penalty in such manner ... file of ld. CIT(Appeals) to examine the additional ground raised before the Tribunal and adjudicate the matter afresh after giving opportunity of being heard to the assessee, since certain facts require verification as contended by the ld. D.R. Therefore, we set aside the order passed

Saviour Commotrade Pvt. Ltd., Kolkatta vs. Income Tax Officer Ward 11(1), Kolkatta, (Order Passed by NFAC, Delhi)

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

ITA 2567/KOL/2024[2013-14]Status: DisposedITAT Kolkata31 Oct 2025AY 2013-14

Bench: Shri George Mathan, Jm & Shri Rakesh Mishra, Am Saviour Commotrade Pvt. Ltd. Income Tax Officer, Ward 11(1) 6, Judges Court Road, Kolkata, Aaykar Bhawan, Vs. Pin-700027, West Bengal Kolkata-700027, West Bengal (Respondent) (Appellant) Pan No. Aamcs3660D Assessee By : Shri Nisheeth Doshi, Ar Revenue By : Shri Raja Sengupta, Dr Date Of Hearing: 30.10.2025 Date Of Pronouncement: 30.10.2025 O R D E R Per George Mathan, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of The National Faceless Appeal Centre, Delhi [The Learned Cit (A)] (Hereinafter Referred To As The “Ld. Cit(A)”] In Appeal No. Itba/Nfac/S/250/2024-25/1070298542(1) Dated 12.11.2024 For The Ay 2013-14. 02. Shri Nisheeth Doshi Appeared On Behalf Of The Assessee & Raja Sengupta Appeared On Behalf Of The Revenue.

For Appellant: Shri Nisheeth Doshi, ARFor Respondent: Shri Raja Sengupta, DR

issues in this appeal are restored to the file of the ld. CIT (A) for adjudication on merits after granting assessee adequate opportunity of being heard. The assessee should be granted adequate opportunity to produce its directors as also the directors of the various persons who have given the assessee

Bimla Devi Agrawal, Kolkata vs. A.C.I.T./D.C.I.T., Circle - 34, Kolkata

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

ITA 1690/KOL/2024[2017-2018]Status: DisposedITAT Kolkata31 Oct 2025AY 2017-2018

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 142(1)Section 143(2)Section 143(3)Section 153Section 155(15)Section 250

I.T.A. No.: 1690/KOL/2024 Assessment Year: 2017-18 Bimla Devi Agrawal. produce and any other evidence in his possession gathered, after giving an opportunity of being heard to the assessee. (5) The Valuation Officer may estimate the value of the asset, property or investment to the best of his judgment ... section (1). (7) The Assessing Officer may, on receipt of the report from the Valuation Officer, and after giving the assessee an opportunity of being heard, take into account such report in making the assessment or reassessment. Explanation.—In this section, "Valuation Officer" has the same meaning as in clause

Olympia Tech Park (Chennai) Pvt. Ltd., Chennai vs. ACIT, Circle-1, Ltu, Chennai

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

ITA 1033/CHNY/2025[2013-14]Status: DisposedITAT Chennai31 Oct 2025AY 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.1033/Chny/2025 िनधा9रण वष9 /Assessment Year: 2013-14 Olympia Tech Park (Chennai) Pvt. The Asst. Commissioner Of Ltd., Vs. Income Tax, (Successor Of Khivraj Tech Park), Circle-1, Ltu, No1, Sidco Industrial Estate, Chennai. Guindy, Chennai – 600 032. Pan: Aabco 8102F

For Appellant: Shri Bhabagrahi DashFor Respondent: Shri Bipin C.N, CIT
Section 143(3)Section 154Section 80I

Learned Authorised Representative (Ld. A.R) for the assessee submitted that the Ld. CIT(A) had dismissed the appeal without providing adequate opportunity of being heard. It was, therefore, requested that one more opportunity may kindly be granted to the assessee for proper representation of its case. 5. On the other ... appeal Olympia Tech Park (Chennai) P. Ltd. :- 4 -: afresh along with the appeal pending on 143(3) order, after affording due opportunity of being heard to the assessee. 7. In the result, the appeal filed by the assessee is allowed. Order pronounced on 31st day of October, 2025 at Chennai

Rajya Vokkaligara Sangha, Bangalore vs. Additional Commissioner of Income Tax(Exemptions), Bangalore

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

ITA 815/BANG/2025[2013-14]Status: DisposedITAT Bangalore31 Oct 2025AY 2013-14

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. Bharath L, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 11Section 12ASection 143(2)

issue with regard to the issue raised by the assessee as stated in the grounds of appeal and after giving reasonable opportunity of being heard decide the issue as per law and assessee is directed to substantiate its case with documentary evidence. In case of failure no second leniency shall

Rajya Vokkaligara Sangha, Bangalore vs. Additional Commissioner of Income Tax(Exemptions), Bangalore

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

ITA 814/BANG/2025[2011-12]Status: DisposedITAT Bangalore31 Oct 2025AY 2011-12

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. Bharath L, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 11Section 12ASection 143(2)

issue with regard to the issue raised by the assessee as stated in the grounds of appeal and after giving reasonable opportunity of being heard decide the issue as per law and assessee is directed to substantiate its case with documentary evidence. In case of failure no second leniency shall

Techmill Technologies Private Limited, Mysore vs. Assistant Commissioner of Income Tax Circle 1(1) & Tps, Mysore

In the result, appeal filed by the assessee is allowed

ITA 498/BANG/2025[2016-17]Status: DisposedITAT Bangalore31 Oct 2025AY 2016-17

Bench: Shri.Laxmi Prasad Sahu & Shri.Keshav Dubeyassessment Year : 2016-17 M/S. Techmill Technologies Pvt. Ltd., Vs. Acit, 2Nd No.34, Floor, Ramanjaneya Circle – 1(1) & Tps, Complex, Hunsur Main Road, Mysuru. Manasagangothri, Mysuru – 570 006, Karnataka. Pan : Aadct 0474 D Appellant Respondent Assessee By : Shri. Siddesh N Gaddi, Ca Revenue By : Shri. Subramanian S, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 27.10.2025 Date Of Pronouncement : 31.10.2025

For Appellant: Shri. Siddesh N Gaddi, CAFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bangalore
Section 142(1)Section 143(2)Section 250Section 271(1)(b)Section 40a

assessee. Assessee has to show the proof of payment of cost to the AO before giving OGE. Needless to say that reasonable opportunity of being heard be given to the assessee. Accordingly, we allow appeal of the assessee is allowed. 10. In the result, appeal filed by the assessee

Sri Sathya Sai Loka Seva Welfare Trust, Bangalore vs. Commissioner of Income Tax, Exemptions, Bangalore

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

ITA 1378/BANG/2025[2024-25]Status: DisposedITAT Bangalore31 Oct 2025AY 2024-25

Bench: Shri.Laxmi Prasad Sahu & Shri.Keshav Dubeyassessment Year : 2024-25 M/S. Sri Sathya Sai Loka Seva Welfare Trust, Vs. Cit(E), 313-D 9Th A Main 5Th Block, Jayanagar, Bangalore. Bangalore – 560 041, Karnataka. Pan : Aawts 7686 Q Appellant Respondent Assessee By : Shri. Raghunandan, Ca Revenue By : Shri. Muthu Shankar, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 28.10.2025 Date Of Pronouncement : 31.10.2025

For Appellant: Shri. Raghunandan, CAFor Respondent: Shri. Muthu Shankar, CIT(DR)(ITAT), Bangalore

light of observations made by the learned CIT(E) in the previous Order and decide the issue as per law after giving reasonable opportunity of being heard to the assessee. Assessee is directed to substantiate its case with cogent documents and not take unnecessary adjournments for early disposal

Standard Chartered (India) Modeling and Analytics Centre Private Limited, East and West Wing vs. Deputy Commissioner of Income Tax - Circle 1(3)(1), Aayakar Bhawan, Mumbai

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

ITA 5526/MUM/2025[2022-23]Status: DisposedITAT Mumbai31 Oct 2025AY 2022-23

Bench: Shri Vikram Singh Yadav, Hon’Ble & Ms. Kavitha Rajagopal, Hon’Ble

For Appellant: Shri Siddesh Gaddi, C.A. (virtually appeared)For Respondent: Shri Hemanshu Joshi, Sr. D/R
Section 139(1)Section 143(1)Section 249(3)Section 250

technical issues. We, therefore, direct the ld. CIT(A) to pass a speaking order on the merits of the case after giving sufficient opportunity of being heard to the assessee on the merits and in accordance with law. The assessee is also directed to co-operate with the proceedings before

Standard Chartered (India) Modeling and Analytics Centre Private Limited, Bangalore Karnataka vs. Deputy Commissioner of Income Tax Cirrcle 1(3)1, Mumbai

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

ITA 5525/MUM/2025[2021-22]Status: DisposedITAT Mumbai31 Oct 2025AY 2021-22

Bench: Shri Vikram Singh Yadav, Hon’Ble & Ms. Kavitha Rajagopal, Hon’Ble

For Appellant: Shri Siddesh Gaddi, C.A. (virtually appeared)For Respondent: Shri Hemanshu Joshi, Sr. D/R
Section 139(1)Section 143(1)Section 249(3)Section 250

technical issues. We, therefore, direct the ld. CIT(A) to pass a speaking order on the merits of the case after giving sufficient opportunity of being heard to the assessee on the merits and in accordance with law. The assessee is also directed to co-operate with the proceedings before

Zahid Abdullah Lakhani, Mumbai vs. Income Tax Officer, Mumbai

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

ITA 5240/MUM/2025[2016-17]Status: DisposedITAT Mumbai31 Oct 2025AY 2016-17

Bench: Shri Rahul Chaudhary & Smt.Renu Jauhri

For Appellant: Mr. Vaseem AhmadFor Respondent: Shri Sandeep Jumale- Sr. DR
Section 133ASection 144Section 147Section 250

learned authorities have erred in law and on facts in passing the order u/s 144 r.w.s.147 without providing adequate and reasonable opportunity of being heard, thereby violating the principles of natural justice. 4. The learned CIT(A) failed to appreciate that the alleged cash sales, even if accepted, are gross

Zahid Abdullah Lakhani, Mumbai vs. Income Tax Officer, Mumbai

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

ITA 5239/MUM/2025[2015-16]Status: DisposedITAT Mumbai31 Oct 2025AY 2015-16

Bench: Shri Rahul Chaudhary & Smt. Renu Jauhri

For Appellant: Mr. Vaseem AhmadFor Respondent: Shri Sandeep Jumale- Sr. DR
Section 133ASection 144Section 147Section 250

learned authorities have erred in law and on facts in passing the order u/s 144 r.w.s.147 without providing adequate and reasonable opportunity of being heard, thereby violating the principles of natural justice. 4. The learned CIT(A) failed to appreciate that the alleged cash sales, even if accepted, are gross

Zahid Abdullah Lakhani, Mumbai vs. Income Tax Officer, Mumbai

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

ITA 5238/MUM/2025[2014-15]Status: DisposedITAT Mumbai31 Oct 2025AY 2014-15

Bench: Shri Rahul Chaudhary & Smt.Renu Jauhri

For Appellant: Mr. Vaseem AhmadFor Respondent: Shri Sandeep Jumale- Sr. DR
Section 133ASection 144Section 147Section 250

learned authorities have erred in law and on facts in passing the order u/s 144 r.w.s.147 without providing adequate and reasonable opportunity of being heard, thereby violating the principles of natural justice. 4. The learned CIT(A) failed to appreciate that the alleged cash sales, even if accepted, are gross

Prakash Mahadev Gaikwad, Belapur vs. Commissioner of Income-Tax (Appeals), Delhi

In the result assessee appeal is allowed for statistical purposes

ITA 5209/MUM/2025[2014-15]Status: DisposedITAT Mumbai31 Oct 2025AY 2014-15

Bench: Shri Narender Kumar Choudhryassessment Year: 2014-15 Prakash Mahadev Gaikwad Commissioner Of 53, Royal Castle, Plot No. 75, Income-Tax (Appeals) Sector- 19/20 Palm Beach Commissioner Of Income Vs. Road, Belapur, Navi Mumbai Tax Appeal Mumbai 46, Pan: Adqpg0694P Ward 42(3)(1), Kautilya Bhavan, Mumbai, Ito 42(3)(1), Mumbai (Appellant) (Respondent) Present For: Assessee By : None Revenue By : Shri Praveen K. Srivastav, Ld. Sr.D.R. Date Of Hearing : 09.10.2025 Date Of Pronouncement : 31.10.2025 O R D E R Per : Narender Kumar Choudhry: This Appeal Has Been Preferred By The Assessee Against The Order Dated 26.06.2025, Impugned Herein, Passed By The National Faceless Appeal Center (Nfac)/ Ld. Commissioner Of Income Tax (Appeals) (In Short Ld. Cit(A)) U/S 250 Of The Income Tax Act, 1961 (In Short ‘The Act’) For The A.Y. 2014-15. 2. Admittedly In The Instant Case, The Ld. Commissioner In The Appeal Filed By The Assessee Against The Assessment Order Dated 27.12.2016 U/S 143(3) Of The Act, Whereby 3 Additions Of Rs. 51,14,040, Rs. 81,94,000/- & 1,44,998/- Were Respectively Made On Account Of Unexplained Investment U/S 69 Of The Act, Unexplained Cash Credit U/S 68 Of The Act & Disallowance On 2 Prakash Mahadev Gaikwad Account Of Interest Income Without Seeking Exemption U/S 80Tt Of The Act, Issued Various Notices To The Assessee, However, The Assessee Failed To Comply With The Same & Therefore In The Constrained Circumstance, The Ld. Commissioner Affirmed The Aforesaid Addition By Dismissing The Appeal Of The Assessee.

For Appellant: NoneFor Respondent: Shri Praveen K. Srivastav, Ld. Sr.D.R
Section 143(3)Section 250Section 68Section 69Section 80T

Revenue Department in “other heads” within 15 days of the receipt of this order. Suffice to say, the Ld. Commissioner shall afford reasonable opportunity of being heard to the assessee. This court clarifies that in case of the subsequent default, the Assessee shall not be entitled to any leniency

Poonam Singh, Mumbai vs. Commissioner of Income Tax-Appeals, Delhi

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

ITA 5156/MUM/2025[2021-22]Status: DisposedITAT Mumbai31 Oct 2025AY 2021-22

Bench: Shri Narender Kumar Choudhryassessment Year: 2021-22

For Appellant: Shri Varun Sharma, Ld. ARFor Respondent: Shri Nakul Agrawal, Ld. Sr.D.R
Section 144Section 250Section 50C

inclined to remand the instant case to the file of the ld. commissioner for decision afresh, suffice to say by affording a reasonable opportunity of being heard to the assessee, however, subject to deposit of Rs. 5000/- in the Revenue Department under “other heads” within 15 days of the receipt

Ramnikkumar Hirachand Togani, Mumbai vs. ITO 23(3)(6), Mumbai

Appeal is allowed for statistical purposes

ITA 5133/MUM/2025[2013-14]Status: DisposedITAT Mumbai31 Oct 2025AY 2013-14

Bench: the Tribunal on the grounds reproduced at Paragraph 2 above.

For Appellant: Shri Ramnikkumar H. ToganiFor Respondent: Shri Annavaran Kosuri
Section 143(3)Section 249(2)

Learned CIT(A) is set aside with the directions to adjudicate the appeal on merits after granting the Assessee a reasonable opportunity of being heard. 8. In terms of above, the present appeal is allowed for statistical purposes. Order pronounced on 31.10.2025. (Om Prakash Kant) Judicial Member म ुंबई Mumbai