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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

Pottolil Agro Mills, Perumbavoor vs. Income Tax Officer, Aluva

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

ITA 664/COCH/2025[2017-18]Status: DisposedITAT Cochin30 Oct 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm

For Appellant: Shri Mathew Joseph, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 115BSection 143(3)Section 2(1)(a)Section 250Section 3Section 69A

customer ledgers to ascertain the genuineness of the cash deposits made during the demonetization period. The assessee shall be afforded a proper opportunity of being heard and to furnish all relevant evidence in support of its claim. In view of the above discussion, the appeal of the assessee is allowed

Amphenol Fci India Private Limited, Kochi vs. DCIT Corporate Circle 1(1), Kochi

In the result, appeal of the assessee bearing ITA

ITA 619/COCH/2025[2016-17]Status: DisposedITAT Cochin30 Oct 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2016-17 Amphenol Fci India Pvt. Ltd. .......... Appellant Xxix/2089 Tripunithura Road, Thykoodam Vyttila S.O., Kochi 682019 [Pan: Aaaco2006R] Vs. Dcit, Corporate Circle-1(1), Kochi ......... Respondent Assessee By: Shri Govind Shekhar, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 28.10.2025 Date Of Pronouncement: 30.10.2025

For Appellant: Shri Govind Shekhar, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(2)Section 143(3)Section 250

accordance with law and decide the matter only related to the addition amount to Rs. 16,04,644/- after granting a reasonable opportunity of being heard to 4 Amphenol FCI India Pvt. Ltd. the assessee. We make it clear that we have not expressed any opinion on the merits

Gopu Nandilath Gopalakrishnan, Thrissur vs. ACIT(2)(1), Thrissur

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

ITA 617/COCH/2025[2017-18]Status: DisposedITAT Cochin30 Oct 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2017-18 Gopu Nandilath Gopalakrishnan .......... Appellant Guruvayoor Road, Punkunnam, Thrissur 680002 [Pan: Accpg7719G] Vs. Asst. Commissioner Of Income Tax-2, Thrissur ......... Respondent Assessee By: Shri Anil D. Nair, Advocate Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 28.10.2025 Date Of Pronouncement: 30.10.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi (Nfac) Dated 12.08.2025 For Assessment Year (Ay) 2017-18. 2. Brief Facts Of The Case Are That The Appellant Is An Individual Engaged In The Business Of Dealing In Domestic Appliances. The Return Of Income For Ay 2017-18 Was Filed On 03.11.2017 Disclosing Income Of Rs. 2,06,37,450/-. Against The Said Return Of Income, The Assessment Was Completed By The Acit, Circle 2(1), Thrissur

For Appellant: Shri Anil D. Nair, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 145A

revalue the opening stock as well on the same basis as adopted for revaluation of the closing stock after affording opportunity of being heard to the assessee. 9. In the result, the appeal filed by the assessee stands partly allowed for statistical purposes. Order pronounced in the open court

Mr. Anil, Ernakulam vs. ITO Non Corp Ward-1(1), Kochi

In the result, the appeals of the assessee bearing ITA Nos 614 &

ITA 615/COCH/2025[2017-18]Status: DisposedITAT Cochin30 Oct 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm

For Appellant: Shri C.V. Vishnu Das KFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 147Section 148Section 250Section 271A

case, so as not to prejudice the proceedings before the Ld. CIT(A). Needless to add, the assessee shall be afforded a reasonable opportunity of being heard before the appellate order is passed. At the same time, the assessee is expected to be diligent and co-operative

Mr. Anil, Ernakulam vs. ITO, Non Corp Ward-1(10, Kochi

In the result, the appeals of the assessee bearing ITA Nos 614 &

ITA 614/COCH/2025[2017-18]Status: DisposedITAT Cochin30 Oct 2025AY 2017-18

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm

For Appellant: Shri C.V. Vishnu Das KFor Respondent: Smt. Leena Lal, Sr. D.R
Section 139(1)Section 147Section 148Section 250Section 271A

case, so as not to prejudice the proceedings before the Ld. CIT(A). Needless to add, the assessee shall be afforded a reasonable opportunity of being heard before the appellate order is passed. At the same time, the assessee is expected to be diligent and co-operative

Pavana Manuel Xavier, Ernakulam vs. ITO, Corporate Ward-2(3), Kochi

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

ITA 589/COCH/2025[2020-21]Status: DisposedITAT Cochin30 Oct 2025AY 2020-21

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2020-21 Pavana Manuel Xavier .......... Appellant Pavana House, Kadavnthara Road Ernakulam 682020 [Pan: Aacpx0280F] Vs. Ito, Corporate Ward - 2(3), Kochi ......... Respondent Assessee By: Shri Padmanathan, Advocate Revenue By: Shri Sanjit Kumar Das, Cit-Dr Date Of Hearing: 28.10.2025 Date Of Pronouncement: 30.10.2025

For Appellant: Shri Padmanathan, AdvocateFor Respondent: Shri Sanjit Kumar Das, CIT-DR
Section 143(3)Section 144BSection 263

PCIT for fresh consideration. The Ld. PCIT shall re-examine the issue afresh after providing the assessee a proper and reasonable opportunity of being heard and to furnish necessary evidences in support of its contentions. We make it clear that we have not expressed any opinion on the merits

Jayganga Exim India Private Limited, Indore vs. ACIT Central-2, Bhopal

In the result “Impugned Order” is set aside and penalty at

ITA 213/IND/2025[2018-19]Status: DisposedITAT Indore30 Oct 2025AY 2018-19

Bench: Dr. Manish Borad & Shri Paresh M Joshi

Section 147Section 148Section 246ASection 250Section 253Section 271(1)(b)

Assessing Officer. Accordingly, the plea of the appellant that penalty levied u/s 271(1)(b) for the A.Y. under consideration without giving reasonable opportunity of being heard is not sustainable and therefore, the claim of the appellant on these grounds are not acceptable. 4.1.3 In view of above discussions ... case Ld. AO has erred in passing and Ld. CIT (A)-3, Bhopal has erred in confirming the impugned order without affording any opportunity of being heard against the principles of natural justice. 3.That the appellant craves leave to add, amend, alter or delete all or any of the grounds

Jayganga Exim India Private Limited, Indore vs. ACIT Central-2, Bhopal

ITA 212/IND/2025[2015-16]Status: DisposedITAT Indore30 Oct 2025AY 2015-16

Bench: Dr. Manish Borad & Shri Paresh M Joshi

Section 147Section 148Section 246ASection 250Section 253Section 271(1)(b)

Assessing Officer. Accordingly, the plea of the appellant that penalty levied u/s 271(1)(b) for the A.Y. under consideration without giving reasonable opportunity of being heard is not sustainable and therefore, the claim of the appellant on these grounds are not acceptable. 4.1.3 In view of above discussions ... case Ld. AO has erred in passing and Ld. CIT (A)-3, Bhopal has erred in confirming the impugned order without affording any opportunity of being heard against the principles of natural justice. 3.That the appellant craves leave to add, amend, alter or delete all or any of the grounds

Jayganga Exim India Private Limited, Indore vs. ACIT Central-2, Bhopal

The appeal of the assessee is allowed

ITA 211/IND/2025[2018-19]Status: DisposedITAT Indore30 Oct 2025AY 2018-19

Bench: Dr. Manish Borad & Shri Paresh M Joshiassessment Year: 2018-19

Section 129Section 142(1)Section 144Section 246ASection 250Section 253Section 271(1)(d)Section 69C

case Ld. AO has erred in passing and Ld. CIT (A)-3, Bhopal has erred in confirming the impugned order without affording any opportunity of being heard against the principles of natural justice. Page 3 of 7 Jayganga Exim India Pvt Ltd. A.Y. 2018-19 4.That the Impugned assessment

Jayant Security and Finance Limited, Indore vs. ACIT Central-2, Bhopal

In the result “Impugned Order” is set aside and penalty at

ITA 210/IND/2025[2016-17]Status: DisposedITAT Indore30 Oct 2025AY 2016-17

Bench: Dr. Manish Borad & Shri Paresh M Joshiassessment Year: 2016-17

Section 142Section 147Section 148Section 246ASection 250Section 253Section 271(1)(b)

case Ld. AO has erred in passing and Ld. CIT (A)-3, Bhopal has erred in confirming the impugned order without affording any opportunity of being heard against the principles of natural justice. 3. That the appellant craves leave to add, amend, alter or delete

Maharishi Markandeyasushrut Sewa Sansthan, Kanti Nagar vs. Anil Kumar Bhardwaj (CIT Exemption), Jaipur

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

ITA 1234/JPR/2024[2023-2024]Status: DisposedITAT Jaipur30 Oct 2025AY 2023-2024

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Anoop Bhatia, CAFor Respondent: Mrs. Alka Gautam, CIT –DR,(Thru: V.C.)
Section 12A

between the parties has to be decided on merits so that nobody’s rights could be scuttled down without providing the proper opportunity of being heard and thereby the principles of natural justice to be followed. Looking to that aspect of the matter we direct the assessee trust to provide

Gajiben Mahotji Thakor, Ahmedabad vs. The Income Tax Officer, Ward-3(3)(8), Ahmedabad

In the result, appeal filed by the assessee is dismissed

ITA 324/AHD/2023[2011-12]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2011-12

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI SIDDHARTHA NAUTIYAL (Judicial Member)

For Appellant: Shri Ketan Shah, Advocate & ShriFor Respondent: Shri Abhijit, Sr.DR
Section 143(2)Section 147Section 148Section 151Section 250Section 45

General or Director General or Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner may, after giving the assessee a reasonable opportunity of being heard in the matter, wherever it is possible to do so, and after recording his reasons for doing so, transfer any case from ... Chief Commissioner or Principal Commissioner or Commissioner from whose jurisdiction the case is to be transferred may, after giving the assessee a reasonable opportunity of being heard in the matter, wherever it is possible to do so, and after recording his reasons for doing so, pass the order; (b) where

Bundy India Limited, Vadodara vs. The Dy. CIT., Circle-1(1), Baroda

In the result, Ground Number 6 of the assessee’s appeal is allowed for statistical purposes

ITA 1403/AHD/2016[2009-10]Status: DisposedITAT Ahmedabad30 Oct 2025AY 2009-10

Bench: Annapurna Gupta & Shri Siddhartha Nautiyalआयकर अपील सं /Ita No.1403/Ahd/2016 िनधा"रण वष" /Assessment Year : 2009-10 Bundy India Limited The Dy.Cit बनाम/ Plot No.2, Circle-1(1) V/S. Gidc Industrial Estate, Baroda Makarpura Vadodaria - 390 010 "थायी लेखा सं./Pan: Aaacb 3039 M (अपीलाथ"/ Appellant) ("" यथ"/ Respondent) Assessee By : Shri S.N. Soparkar, Sr. Advocate Revenue By : Shree Veerbadram Vislavath, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 31/07/2025 घोषणा की तारीख /Date Of Pronouncement: 30/10/2025 आदेश/O R D E R Per Siddhartha Nautiyal, Jm:

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shree Veerbadram Vislavath, Sr.DR
Section 133(6)Section 250Section 92CSection 92C(1)Section 92C(3)

ITES segment in accordance with law and in the light of the directions contained herein. The assessee shall be afforded reasonable opportunity of being heard and to furnish necessary documentation in support of its contentions. 15. In the result, the ground of appeal relating to the ITES segment adjustment ... ordinate Bench of this Tribunal in the assessee’s own case for AY 2007–08 (supra). The assessee shall be afforded due opportunity of being heard and to furnish necessary documentation in support of its claim. Bundy India Ltd. vs. DCIT Asst. Year : 2009-10 25. In the result, Ground

Satyamev Nagari Sahakari Patsanstha Maryadit, Nashik vs. Income Tax Officer - Ward 1(1), Nashik

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

ITA 2036/PUN/2025[2021-22]Status: DisposedITAT Pune30 Oct 2025AY 2021-22

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2036/Pun/2025 निर्धारण वषा / Assessment Year: 2021-22 Satyamev Nagari Sahakari V The Income Tax Officer, Patsanstha Maryadit, S Ward-1(1), Nashik. 1, Maratha Tower, Raviwar Karanja, Nashik – 422001. Maharashtra. Pan: Aakas2833C Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Eknath Abhang – Add.Cit(Dr) Date Of Hearing 30/10/2025 Date Of Pronouncement 30/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2021-22 Dated 17.06.2025 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144B Of The Income Tax Act, 1961 Dated

Section 147Section 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)Section 80P

prayed that the matter may please be set aside to the file of the A.O. for conducting asst. afresh after granting one more opportunity of being heard, in the interest of justice. 31 and Without prejudice to the above grounds, the appellant submits that there was a reasonable cause ... notices and therefore, the matter may please be set aside to the file of the CIT(A) for fresh adjudication after granting proper opportunity of being heard. 4] Without prejudice to the above grounds, the appellant submits that the disallowance of deduction u/s 80P of Rs.33,16,502 made

Rashmi Arun Chougule, Kolhapur vs. Income Tax Officer Ward 2(1), Kolhapur

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

ITA 1892/PUN/2025[A.Y. 2014-15]Status: DisposedITAT Pune30 Oct 2025

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.1892/Pun/2025 निर्धारण वषा / Assessment Year: 2014-15 Rashmi Arun Chogule, V The Income Tax Officer, 1557, D Ward, Dhanawade S Ward-2(1), Kolhapur. Galli, Shukrawarpeth, Kolhapur – 416002. Maharashtra. Pan: Aehpc4149R Appellant/ Assessee Respondent / Revenue Assessee By None Revenue By Shri Eknath Abhang – Add.Cit(Dr) Date Of Hearing 30/10/2025 Date Of Pronouncement 30/10/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2014-15 Dated 20.06.2025 Emanating From The Penalty Order Passed Under Section 271(1)(C) Of The Income Tax Act, 1961 Dated 14.09.2022. The Assessee Has Raised The Following Grounds Of Appeal :

Section 250Section 271(1)(c)Section 69

said penalty is unjustified, arbitrary, and bad in law. 4 The learned CIT(A) erred in dismissing the appeal without granting an effective opportunity of being heard, thereby violating the principles of natural justice. 5 The appellant craves leave to add, amend, modify, alter, revise, substitute, delete

Gopa Ghosh Chanda, Cooch Behar, Dinhata vs. ITO Ward-2(1), Cooch Behar

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

ITA 885/KOL/2025[2013-14]Status: DisposedITAT Kolkata30 Oct 2025AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 885/Kol/2025 Assessment Year: 2013-2014 Gopa Ghosh Chanda,………………………….……Appellant C/O. Kaushik Chanda, Madan Mohan Para, Dinhata, Coochbehar-736135, W.B. [Pan:Ayppg9182N] -Vs.- Income Tax Officer,…………………………..…..Respondent Ward-2(1), Coochbehar

Section 115BSection 142(1)Section 147Section 148Section 69A

assessee argued before the Bench that the ld. CIT(Appeals) passed the order without going into merit of the case and giving sufficient opportunity of being heard. Therefore, ld. Counsel pleaded to set aside the order passed by the ld. CIT(Appeals) and remit the matter back to the file ... from the impugned order of the ld. CIT(Appeals), I am of the view that proper and sufficient opportunity of being heard cannot be said to have been given by the ld. CIT(Appeals) to the assessee before dismissing the appeal of the assessee. There is a clear violation

Birbhum District Central Cooperative Bank Limited, Birbhum vs. ITO, TDS, Ward 4(1), Durgapur

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

ITA 768/KOL/2025[2017-2018]Status: DisposedITAT Kolkata30 Oct 2025AY 2017-2018

Bench: Shri George Mathan, Jm & Shri Rakesh Mishra, Am

For Appellant: Shri S.K. Tulsiyan &For Respondent: Shri Raja Sengupta, CIT DR

issues in these appeals are restored to the file of the ld. CIT (A) for re- adjudication after granting the assessee adequate opportunity of being heard. 05. In the result, the appeals of the assessee are allowed for statistical purposes. Order pronounced in the open court on 30.10.2025. (RAKESH MISHRA

Micky Metals Limited, Kolkata vs. ITO, Ward 3(1), Kolkata

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

ITA 269/KOL/2025[2022-23]Status: HeardITAT Kolkata30 Oct 2025AY 2022-23

Bench: Shri George Mathan, Jm & Shri Rakesh Mishra, Am Income Tax Officer, Micky Metals Limited Ward 3(1), 1St Floor Suite No.103, Aayakar Bhawan Kolkata, Haute Street, Cororate Park, Vs. P-7, Chowringhee Square, Topsia, Kolkata-700046 Kolkata-700069, West Bengal (Appellant) (Respondent) Pan No. Aadcm2196H Assessee By : Shri Amit Agarwal, Ar Revenue By : Shri Sallong Yaden, Dr Date Of Hearing: 30.10.2025 Date Of Pronouncement: 30.10.2025 O R D E R Per George Mathan, Jm:

For Appellant: Shri Amit Agarwal, ARFor Respondent: Shri Sallong Yaden, DR

breath, we restore the appeal to the file of the learned CIT (A) to decide the appeal on merit after affording a reasonable opportunity of being heard to the assessee. 06. In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced in the open court

M/S. Midnapur Timber Traders, West Midnapur vs. ITO, NFAC, Delhi

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

ITA 1616/KOL/2025[2022-2023]Status: DisposedITAT Kolkata30 Oct 2025AY 2022-2023

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 145(3)Section 250Section 68

Bench that the request of the assessee to remand the case before the Ld. AO may be allowed so that a proper opportunity of being heard may be provided. Hence, after examining the facts of the case, we deem it appropriate to set aside the order ... matter back to the Ld. AO for making the reassessment de novo. Needless to say, the assessee shall be given a reasonable opportunity of being heard to make any further submission it wants to make in support of its grounds of appeal and shall not seek unnecessary adjournments. Accordingly

Melco Sales Private Limited, Mumbai (Maharashtra) vs. Income Tax Officer, Ward - 9(1), Kolkata, Kolkata (West Bengal)

In the result, the appeal is allowed for statistical purposes

ITA 1604/KOL/2025[2009-10]Status: DisposedITAT Kolkata30 Oct 2025AY 2009-10

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 144Section 147Section 148Section 234BSection 250Section 68

fair play it was considered appropriate to remand the matter to the Ld. AO for framing the assessment afresh after according an opportunity of being heard to the assessee. Accordingly, the order of the Ld. CIT(A) is hereby set aside and the matter is I.T.A. No.: 1604/KOL/2025 Assessment Year ... Melco Sales Private Limited. remanded to the Ld. AO for making the assessment de novo. The assessee shall be provided an opportunity of being heard by providing the reasons for reopening of the assessment so as to enable it to make proper submission. Accordingly, all the grounds taken