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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

Pioneer E Solution Private Limited, New Delhi vs. DCIT, Circle-19(1), Delhi

In the result, the order of the CIT(A) is set aside and the appeal of the assessee is partly allowed

ITA 5362/DEL/2024[2020-21]Status: DisposedITAT Delhi28 Oct 2025AY 2020-21

Bench: Ms. Madhumita Roy & Shri Naveen Chandraassessment Year: 2020-21

Section 115BSection 143(1)Section 154

appellant due to lack of principles of natural justice or violation of principles of natural justice. 6) That the Appellant prays for an opportunity of being heard in person through representative and the grant of permission to add, alter, delete, modify, any or all of the grounds of appeal ... filed and order was passed by the Learned AO on 01.07.2022 without giving any show cause notice or opportunity of being heard to the assessee as the case made out by the assessee, charging total income at 30% including the provisions of the Income-tax Act that in case

Assistant Commissioner of Income Tax, New Delhi vs. Karnal Agricultural Industries Limited, Delhi

Appeals stand allowed for statistical purposes

ITA 4543/DEL/2024[2016-17]Status: DisposedITAT Delhi28 Oct 2025AY 2016-17

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumar

For Appellant: Sh. Mayank Patwari, FCA & Sh. Akash OjhaFor Respondent: Sh. Om Prakash, Sr. DR
Section 143(2)Section 144Section 144BSection 147Section 69

interest of justice, the issues in dispute are remanded back to the file of the Assessing Officer for fresh adjudication, after giving adequate opportunity of being heard to the assessee. The Assessee through his Ld. AR is also directed to cooperate during 4 | P a g e the assessment proceedings

Assistant Commissioner of Income Tax, New Delhi vs. Karnal Agricultural Industries Limited, Delhi

Appeals stand allowed for statistical purposes

ITA 4542/DEL/2024[2014-15]Status: DisposedITAT Delhi28 Oct 2025AY 2014-15

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumar

For Appellant: Sh. Mayank Patwari, FCA & Sh. Akash OjhaFor Respondent: Sh. Om Prakash, Sr. DR
Section 143(2)Section 144Section 144BSection 147Section 69

interest of justice, the issues in dispute are remanded back to the file of the Assessing Officer for fresh adjudication, after giving adequate opportunity of being heard to the assessee. The Assessee through his Ld. AR is also directed to cooperate during 4 | P a g e the assessment proceedings

Assistant Commissioner of Income Tax, New Delhi vs. Karnal Agricultural Industries Limited, Delhi

Appeals stand allowed for statistical purposes

ITA 4541/DEL/2024[2013-14]Status: DisposedITAT Delhi28 Oct 2025AY 2013-14

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumar

For Appellant: Sh. Mayank Patwari, FCA & Sh. Akash OjhaFor Respondent: Sh. Om Prakash, Sr. DR
Section 143(2)Section 144Section 144BSection 147Section 69

interest of justice, the issues in dispute are remanded back to the file of the Assessing Officer for fresh adjudication, after giving adequate opportunity of being heard to the assessee. The Assessee through his Ld. AR is also directed to cooperate during 4 | P a g e the assessment proceedings

Assistant Commissioner of Income Tax, New Delhi vs. Karnal Agricultural Industries Limited, Delhi

Appeals stand allowed for statistical purposes

ITA 4526/DEL/2024[2017-18]Status: DisposedITAT Delhi28 Oct 2025AY 2017-18

Bench: Sh. M. Balaganesh & Sh. Sudhir Kumar

For Appellant: Sh. Mayank Patwari, FCA & Sh. Akash OjhaFor Respondent: Sh. Om Prakash, Sr. DR
Section 143(2)Section 144Section 144BSection 147Section 69

interest of justice, the issues in dispute are remanded back to the file of the Assessing Officer for fresh adjudication, after giving adequate opportunity of being heard to the assessee. The Assessee through his Ld. AR is also directed to cooperate during 4 | P a g e the assessment proceedings

ACIT, Central Circle, Ghaziabad vs. Kdp Infrastructure Pvt. Ltd, Noida

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

ITA 2177/DEL/2024[2018-19]Status: DisposedITAT Delhi28 Oct 2025AY 2018-19

Bench: Sh. M Balaganesh & Sh. Sudhir Kumarassessment Year: 2018-19 Acit, Central Circle, Vs. Kdp Infrastructure Ghaziabad Pvt. Ltd., Room No. 229, 2Nd Floor, D-247/29, Sector-63, Cgo Complex-I, Hapur Gautam Budh Nagar, Chungi, Ghaziabad Noida, Uttar Pradesh Uttar Pradesh -201002 (Appellant) (Respondent)

Section 142(1)Section 143(2)Section 144(3)Section 68

every additional evidence and consider the same in a proper manner and thereafter decide the issues in dispute afresh, after giving adequate opportunity of being heard to the assessee, to enable him to canvass its case properly before the AO. The assessee through its Ld. AR is also directed

Income Tax Officer, Agra vs. Rameshwar Singh, Agra

In the result, revenue’s appeal is dismissed

ITA 286/AGR/2025[2018-19]Status: DisposedITAT Agra27 Oct 2025AY 2018-19

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2018-19

Section 115BSection 142(1)Section 144Section 147Section 148Section 148ASection 250Section 69ASection 69C

appellate 3 | P a g e proceedings would constitute additional evidences under Rule 46A of the Income-tax Rules, 1962 and hence, an opportunity of being heard to the AO must be provided on additional evidences before being considered in the appellate proceedings…………..” 5. Perused the records. Heard learned

Ganpati Infrastucture Development Company Ltd., Agra vs. Pr.CIT.-1, Agra

ITA 99/AGR/2022[2017-18]Status: DisposedITAT Agra27 Oct 2025AY 2017-18

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 143(1)Section 143(2)Section 143(3)Section 263Section 270A

Agra is hereby cancelled, with the directions to the Assessing Officer to pass a fresh order, de novo, and after affording reasonable opportunity of being heard to the Assessee.” 10. We notice that assessee has filed copy of his partial reply dated 26.03.2022, vide pages (14 to 17) and copy

Xlri Alumuni Association, Jamshedpur vs. Income Tax Officer Exemption Ward, Jamshedpur

ITA 308/RAN/2024[NOT APPLICABLE]Status: DisposedITAT Ranchi27 Oct 2025

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.308/Ran/2024 Xlri Alumuni Association ….……………............................……….……Appellant Xlri Campus, C H Area East, Jamshedpur, Jharkhand – 831001. [Pan: Aaaax0042N] Vs. Ito (Exemption), Jamshedpur...…..….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Ar & R. R. Mittal, Ar, Appeared On Behalf Of The Appellant. Shri Kumar Pranab, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 04, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Cit(Exemption), Patna [“Cit(Exemption)”] Dated 25.05.2024 Rejecting The Application In Form 10Ab For Registration U/S 12A Of The Income-Tax Act, 1961 (The “Act”). 2. Brief Facts Of The Case Are That The Assessee Filed An Application In Form No. 10Ab Seeking Regular Registration Under Clause (Iii) Of Sub- Section (1)(Ac) Of Section 12A, Read With Section 12Ab(1)(B) Of The Act. The Said Application Was Filed For Continuation Of Registration Previously Granted Under Section 12A(1)(Ac)(Vi), Vide Form 10Ac Dated 23.09.2021, For The Assessment Years 2022–23 To 2024–25. 3. During The Course Of Proceedings Under Section 12Ab, The Learned Cit (Exemption) Examined The Objects & Genuineness Of The Activities Of The Applicant Institution & To Verify Compliance With Statutory Requirements, Called Upon The Assessee To Furnish The Following Details: Note On Activities Undertaken During Financial Years 2020–21, 2021–22

Section 12ASection 12A(1)(ac)

primary contention of the assessee is that the learned CIT (Exemption) has rejected the application in a summary manner without affording proper opportunity of being heard and without appreciating the documents and explanations submitted by the assessee during the registration proceedings. 5. The learned Departmental Representative, on the other hand ... examine the documents, activities, and objects of the assessee institution afresh and pass a reasoned order in accordance with law after affording adequate opportunity of being heard to the assessee. The assessee is directed to extend full cooperation and to submit all necessary details and evidence in support

Shri Amitkumar Jasvantlal Doshi, Surendranagar vs. The DCIT, Cir.-4 (1) (1), Ahmedabad

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

ITA 842/RJT/2024[2020-21]Status: DisposedITAT Rajkot27 Oct 2025AY 2020-21

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 842/Rjt/2024 ("नधा"रणवष" / Assessment Year: (2020-21) (Hybrid Hearing) Amitkumar Jasvantlal Doshi Cit(Appeals), Nfac-Delhi, Vs. 16, Ashok Nagar Society, Meghani Road, Dcit, Circ – 4(1)(1), Surendranagar-363001 Ahmedabad "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aazpd3668C (Appellant) (Respondent) Appellant By : Shri Krunal Karia, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 28/07/2025 Date Of Pronouncement : 27/10/2025 आदेश / O R D E R Per Dinesh Mohan Sinha, Jm:

For Appellant: Shri Krunal Karia, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 142(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144Section 250

addition made is hereby sustained in appeal...s." 11. We further note that during the Appellate Proceedings, the appellant had requested for an Opportunity of being heard via Video Conferencing Proceeding in accordance with Para 13 of the E- Appeals Scheme, 2023. The Ld. CIT(Appeals)-NFAC, had never brought

Sangam Almirah Private Limited, Muzaffarpur vs. NFAC, Delhi

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

ITA 338/PAT/2025[2018-19]Status: DisposedITAT Patna27 Oct 2025AY 2018-19

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishra

Section 250Section 270ASection 270A(9)

order accepting or rejecting such application: Provided that no order rejecting the application shall be passed unless the assessee has been given an opportunity of being heard. (5) The order made under sub-section (4) shall be final. (6) No appeal under section 246 or section 246A or an application

Thottipal Service Cooperative Bank, Thrissur vs. ITO Ward 2(5), Thrissur

ITA 552/COCH/2025[2013-14]Status: DisposedITAT Cochin27 Oct 2025AY 2013-14

Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Smt. Divya RavindranFor Respondent: Shri Sanjit Kumar Das
Section 144Section 144BSection 147Section 250Section 69ASection 80P(2)(d)

issue back to the file of the CIT(A) with the directions to adjudicate the appeal afresh after granting the Assessee a reasonable opportunity of being heard. The Assessee directed to co-operate in the appellate proceedings and forthwith file details, documents & submission in support of its claims/contentions before

Saryu Prasad, Barabanki vs. Income Tax Officer-5(4), Barabanki

In the result, the ase’s appeal is partly allowed

ITA 490/LKW/2025[2016-17]Status: DisposedITAT Lucknow27 Oct 2025AY 2016-17

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2016-17 Saryu Prasad V. The Income Tax Officer 5(4) Bhanpur Barabanki Mahulara, Ramsamethi Ghat Barbanki (U.P) Tan/Pan: (Appellant) (Respondent) Appellant By: Shri Samrat Chandra, C.A. Respondent By: Shri R.R.N. Shukla, D.R. O R D E R

For Appellant: Shri Samrat Chandra, C.AFor Respondent: Shri R.R.N. Shukla, D.R
Section 115BSection 142(1)Section 144Section 147Section 148Section 69A

case, the appeal order passed by the Ld. CIT(A) is in absolute violation of the principles of Natural Justice, without providing adequate opportunity of being heard and therefore deserves to be declared a nullity. 12. The appellant craves for leave to add, modify, amend or delete any other

Sahkari Ganna Vikas Samiti Ltd Vikramjot Basti, Vikramjot vs. Inocme Tax Officer Basti -New, Income Tax Office Basti

The appeal of the assessee stands allowed for statistical purposes

ITA 486/LKW/2025[2017-18]Status: DisposedITAT Lucknow27 Oct 2025AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Sahkari Ganna Vikas V. The Income Tax Officer Samiti Ltd. Basti Vikramjot, Basti (U.P) Tan/Pan:Aabas4611B (Appellant) (Respondent) Appellant By: None Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 05.12.2024, Passed By The Addl/Jcit(A)-3, Bengaluru For Assessment Year 2017-18. 2.0 The Brief Facts Of The Case Are That The Assessee Is A Co- Operative Society Registered Under The Co-Operative Societies Act, 1912. The Main Activity Of The Assessee Was Marketing Of Sugar Cane Grown By The Cane Growers, Who Were Members Of The Assessee-Society. The Assessee Filed Its Return Of Income For The Year Under Consideration On 21.03.2018, Declaring A Total Income Of Rs.1,73,170/-. During The Year Under Consideration, The Assessee-Society Had Received Commission From Sugar Mills On Supply Of Sugar Cane Of Rs.70,16,032/-, Which Was Claimed As Exempt In Terms Of Section 80P(2)(A)(Ii) Of The Income Tax Act

For Appellant: NoneFor Respondent: Shri R.R.N. Shukla, D.R
Section 143(3)Section 194HSection 57Section 80PSection 80P(2)(a)

documents, as filed before Hon'ble Supreme Court, will adjudicate the issue afresh. Needless to say that the assessees will be provided sufficient opportunity of being heard.” 14. Subsequent on the said remand, the matter was examined by the Revenue and after consideration of the decision

Mukesh Kumar Singh, Hardoi vs. Income Tax Officer-3(2), Hardoi-/NFAC

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

ITA 485/LKW/2025[2020-21]Status: DisposedITAT Lucknow27 Oct 2025AY 2020-21

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2020-21 Mukesh Kumar Singh V. The Income Tax Officer 3 (2) Sadhinawa Uchwal Hardoi-1/Nfac Hardoi (U.P) Tan/Pan:Bxkps8596P (Appellant) (Respondent) Appellant By: None Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 27.05.2025, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2020-21. 2.0 The Brief Facts Of The Case Are That The Assessee Was Engaged In The Business Of Recovery Of Loans & Emi. The Assessee Had Filed His Return Of Income For The Year Under Consideration Declaring A Total Income Of Rs.18,40,681/-. Subsequently, The Assessee Revised His Return Of Income On 23.11.2020, Declaring A Total Income Of Rs.12,17,600/-. The Case Of The Assessee Was Selected For Scrutiny Under Cass For The Reason That The "Taxable Income Shown In Revised Return Is Less Than The Taxable Income Shown In The Original Return & Large Refund Has Been Claimed (Business Itr) Reduction Of Income In

For Appellant: NoneFor Respondent: Shri R.R.N. Shukla, D.R
Section 144Section 144B

circumstance of the case, the order of Assessment has been passed in absolute violation of the principles of Natural Justice, without providing adequate opportunity of being heard and therefore deserves to be declared a nullity. ITA No.485/LKW/2025 Page 4 of 5 6. The appellant craves for leave to add, modify

Virat Construction, Shahjahanpur vs. ITO-1(4) Shahjahanpur-1, Shahjahanpur

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

ITA 477/LKW/2025[2018-19]Status: DisposedITAT Lucknow27 Oct 2025AY 2018-19

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2018-19 Virat Construction V. The Ito-I(4) Tarin Bahadurganj Shahjahanpur-1 Shahjahanpur (U.P) Tan/Pan:Aapfv3897H (Appellant) (Respondent) Appellant By: None Respondent By: Shri R.R.N. Shukla, D.R. O R D E R

For Appellant: NoneFor Respondent: Shri R.R.N. Shukla, D.R
Section 143(3)Section 145(3)Section 270A

circumstance of the case, the order of Assessment has been passed in absolute violation of the principles of Natural Justice, without providing adequate opportunity of being heard and therefore deserves to be declared a nullity. ITA No.477/LKW/2025 Page 4 of 5 7. The appellant craves for leave to add, modify

Nirmaljit Singh Khatra, Chandigarh vs. ITO, Ward-2(1), Chandigarh

In the result, Assessee’s appeal is allowed for Statistical Purposes

ITA 976/CHANDI/2025[2016-17]Status: DisposedITAT Chandigarh27 Oct 2025AY 2016-17

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 976/Chd/2025 "नधा"रण वष" / Assessment Year : 2016-17 Nirmaljit Singh Khatra, The Ito, बनाम 3010, Sector 38-D, Ward 2(1), Chandigarh Chandigarh Vs. "थायी लेखा सं./ Pan No: Acepk0729N अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Anil Arora, Ca राज"व क" ओर से/ Revenue By : Dr. Ranjit Kaur, Addl. Cit, Sr. Dr (Virtual) सुनवाई क" तार"ख/Date Of Hearing : 13.10.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 27.10.2025 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 28.06.2024 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Pertaining To A.Y. 2016-17. 2. Grounds Of Appeal Are As Under:

For Appellant: Sh. Anil Arora, CAFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 144Section 147Section 148A

Khatra, Chandigarh 2 appreciating the genuine circumstances and reasons for the non-compliance. 2. That the CIT(A) failed to provide a meaningful opportunity of being heard in accordance with the principles of natural justice, despite the appellant being a senior citizen (aged 75 years) suffering from health issues

Kuldip Singh, Chandigarh vs. ITO, Ward-5(5), Chandigarh

In the result, Assessee’s appeal is allowed for Statistical Purposes

ITA 789/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh27 Oct 2025AY 2012-13

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 789/Chd/2025 "नधा"रण वष" / Assessment Year : 2012-13 Sh. Kuldip Singh, The Ito, बनाम 3386, Sector 46C, Ward 5(5), Chandigarh 160047 Chandigarh Vs. "थायी लेखा सं./ Pan No: Bphps0923R अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Parikshit Aggarwal, Ca राज"व क" ओर से/ Revenue By : Sh. Vivek Vardhan, Addl. Cit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 13.10.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 27.10.2025 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 29.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi Pertaining To A.Y. 2012-13. 2. Grounds Of Appeal Are As Under:

For Appellant: Sh. Parikshit Aggarwal, CAFor Respondent: Sh. Vivek Vardhan, Addl. CIT, Sr. DR
Section 148Section 69A

passed by Ld. AO and then by Worthy CIT(A) deserves to be quashed since the same have been passed without affording reasonable opportunity of being heard to the appellant. 6. That the appellant craves leave for any addition, deletion, or amendment in the grounds of appeal on or before

District Election Office Hamirpur, Sub Divisional Magistrate Office, Hamirpur vs. Income Tax Officer, (TDS) Mandi, Mandi

In the result, Assessee’s appeal is allowed for Statistical Purposes

ITA 462/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh27 Oct 2025AY 2018-19

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 462/Chd/2025 "नधा"रण वष" / Assessment Year : 2018-19 District Election Office, The Ito (Tds), बनाम Sub Divisional Magistrate Mandi Office, Vs. Hamirpur 171001 "थायी लेखा सं./ Pan No: Ptldi1969Q अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Vishal Mohan, Sr. Advocate With Sh. Abhinav, Advocate (Virtual) राज"व क" ओर से/ Revenue By : Sh. Vivek Vardhan, Addl. Cit, Sr. Dr सुनवाई क" तार"ख/Date Of Hearing : 13.10.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 27.10.2025 आदेश/Order Per Krinwant Sahay, Am : Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 06.02.2025 Passed By The Ld. Addl. / Joint Commissioner Of Income Tax (Appeals)-9, Mumbai For A.Y. 2018-19. 2. Grounds Of Appeal Are As Under:

For Appellant: Sh. Vishal Mohan, Sr. Advocate with Sh. Abhinav, Advocate (Virtual)For Respondent: Sh. Vivek Vardhan, Addl. CIT, Sr. DR
Section 194CSection 201

order, therefore, in the fitness of the things and keeping in view the element of natural justice, the Assessee should be given an opportunity of being heard. Accordingly, we are inclined to remand this case back to the file of the Assessing Officer for fresh adjudication. 462-Chd-2025 District

Shivam Multispeciality and Accident Care Centre Pvt. Ltd., Pune vs. Income Tax Officer, Pune

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

ITA 696/PUN/2025[2017-2018]Status: DisposedITAT Pune27 Oct 2025AY 2017-2018

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.696/Pun/2025 धििाारण वर्ा / Assessment Year : 2017-18 Shivam Multispecialty & Accident Care Income Tax Officer, Centre Pvt. Ltd., Ward – 6(1), Pune Opp. Manali Resort, Near Dsk Dream City, Vs. Next To Loni Kalbhor Toll Naka, Pune-Solapur Mumbai Bypass Road, Fursungi, Pune-412308, Maharashtra Pan : Aapcs5482A अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Dhiraj Dandgaval Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 27-10-2025 Pronouncement : आदेश / Order

For Appellant: Shri Dhiraj DandgavalFor Respondent: Shri Akhilesh Srivastva
Section 143(2)Section 144Section 68

file of the Ld. CIT(A) / NFAC with a direction to condone the delay and decide the appeal on merit after giving due opportunity of being heard to the assessee. The assessee is also hereby directed to make its submissions, if any, on the date of hearing without seeking