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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

Aarif Ali, Siwan vs. Ac/DCIT, Central Circle, Muzaffarpur

ITA 283/PAT/2025[2018-19]Status: DisposedITAT Patna16 Oct 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.278 To 283/Pat/2025 Assessment Years: 2013-14 To 2018-19 Aarif Ali……………………………….………. …………………....Appellant Son Of Khush Mohammad, Resident Of Village: Sallahpur, P.O Dindayalpur, Ps: G.B Nagar Darwara, Dist: Siwan, Bihar, Pin-841506. [Pan: Bxfpa9056H] Vs. Acit/Dcit, Muzaffarpur....…..……………..………………….…..... Respondent Appearances By: None (Adjournment Petition Filed) Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cir(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 16, 2025 आदेश / Order Per Bench: All These Six Appeals In Ita Nos. 278 To 283/Patna/2025 Have Been Filed By The Same Assessee For Assessment Years 2013–14 To 2018– 19, Respectively. Since The Issues Involved In All These Appeals Are Common Except For Variations In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noted That There Is A Delay Of 95 Days In Filing All The Captioned Appeals. The Assessee Has Filed A Petition Explaining The Reasons For The Delay. After Considering The Submissions And

Section 132ASection 142(1)Section 143(2)Section 153A

restore the matter to the file of the CIT(A) with a direction to re-examine the issue afresh after providing due opportunity of being heard to the assessee. 8. Since the facts and issues in the other connected appeals (ITA Nos. 279 to 282/Patna/2025) for assessment years

Aarif Ali, Siwan vs. Ac/DCIT, Central Circle, Muzaffarpur

ITA 282/PAT/2025[2017-18]Status: DisposedITAT Patna16 Oct 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.278 To 283/Pat/2025 Assessment Years: 2013-14 To 2018-19 Aarif Ali……………………………….………. …………………....Appellant Son Of Khush Mohammad, Resident Of Village: Sallahpur, P.O Dindayalpur, Ps: G.B Nagar Darwara, Dist: Siwan, Bihar, Pin-841506. [Pan: Bxfpa9056H] Vs. Acit/Dcit, Muzaffarpur....…..……………..………………….…..... Respondent Appearances By: None (Adjournment Petition Filed) Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cir(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 16, 2025 आदेश / Order Per Bench: All These Six Appeals In Ita Nos. 278 To 283/Patna/2025 Have Been Filed By The Same Assessee For Assessment Years 2013–14 To 2018– 19, Respectively. Since The Issues Involved In All These Appeals Are Common Except For Variations In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noted That There Is A Delay Of 95 Days In Filing All The Captioned Appeals. The Assessee Has Filed A Petition Explaining The Reasons For The Delay. After Considering The Submissions And

Section 132ASection 142(1)Section 143(2)Section 153A

restore the matter to the file of the CIT(A) with a direction to re-examine the issue afresh after providing due opportunity of being heard to the assessee. 8. Since the facts and issues in the other connected appeals (ITA Nos. 279 to 282/Patna/2025) for assessment years

Aarif Ali, Siwan vs. Ac/DCIT, Central Circle, Muzaffarpur

ITA 281/PAT/2025[2016-17]Status: DisposedITAT Patna16 Oct 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.278 To 283/Pat/2025 Assessment Years: 2013-14 To 2018-19 Aarif Ali……………………………….………. …………………....Appellant Son Of Khush Mohammad, Resident Of Village: Sallahpur, P.O Dindayalpur, Ps: G.B Nagar Darwara, Dist: Siwan, Bihar, Pin-841506. [Pan: Bxfpa9056H] Vs. Acit/Dcit, Muzaffarpur....…..……………..………………….…..... Respondent Appearances By: None (Adjournment Petition Filed) Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cir(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 16, 2025 आदेश / Order Per Bench: All These Six Appeals In Ita Nos. 278 To 283/Patna/2025 Have Been Filed By The Same Assessee For Assessment Years 2013–14 To 2018– 19, Respectively. Since The Issues Involved In All These Appeals Are Common Except For Variations In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noted That There Is A Delay Of 95 Days In Filing All The Captioned Appeals. The Assessee Has Filed A Petition Explaining The Reasons For The Delay. After Considering The Submissions And

Section 132ASection 142(1)Section 143(2)Section 153A

restore the matter to the file of the CIT(A) with a direction to re-examine the issue afresh after providing due opportunity of being heard to the assessee. 8. Since the facts and issues in the other connected appeals (ITA Nos. 279 to 282/Patna/2025) for assessment years

Aarif Ali, Siwan vs. Ac/DCIT, Central Circle, Muzaffarpur

ITA 280/PAT/2025[2015-16]Status: DisposedITAT Patna16 Oct 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.278 To 283/Pat/2025 Assessment Years: 2013-14 To 2018-19 Aarif Ali……………………………….………. …………………....Appellant Son Of Khush Mohammad, Resident Of Village: Sallahpur, P.O Dindayalpur, Ps: G.B Nagar Darwara, Dist: Siwan, Bihar, Pin-841506. [Pan: Bxfpa9056H] Vs. Acit/Dcit, Muzaffarpur....…..……………..………………….…..... Respondent Appearances By: None (Adjournment Petition Filed) Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cir(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 16, 2025 आदेश / Order Per Bench: All These Six Appeals In Ita Nos. 278 To 283/Patna/2025 Have Been Filed By The Same Assessee For Assessment Years 2013–14 To 2018– 19, Respectively. Since The Issues Involved In All These Appeals Are Common Except For Variations In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noted That There Is A Delay Of 95 Days In Filing All The Captioned Appeals. The Assessee Has Filed A Petition Explaining The Reasons For The Delay. After Considering The Submissions And

Section 132ASection 142(1)Section 143(2)Section 153A

restore the matter to the file of the CIT(A) with a direction to re-examine the issue afresh after providing due opportunity of being heard to the assessee. 8. Since the facts and issues in the other connected appeals (ITA Nos. 279 to 282/Patna/2025) for assessment years

Aarif Ali, Siwan vs. Ac/DCIT, Central Circle, Muzaffarpur

ITA 279/PAT/2025[2014-15]Status: DisposedITAT Patna16 Oct 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.278 To 283/Pat/2025 Assessment Years: 2013-14 To 2018-19 Aarif Ali……………………………….………. …………………....Appellant Son Of Khush Mohammad, Resident Of Village: Sallahpur, P.O Dindayalpur, Ps: G.B Nagar Darwara, Dist: Siwan, Bihar, Pin-841506. [Pan: Bxfpa9056H] Vs. Acit/Dcit, Muzaffarpur....…..……………..………………….…..... Respondent Appearances By: None (Adjournment Petition Filed) Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cir(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 16, 2025 आदेश / Order Per Bench: All These Six Appeals In Ita Nos. 278 To 283/Patna/2025 Have Been Filed By The Same Assessee For Assessment Years 2013–14 To 2018– 19, Respectively. Since The Issues Involved In All These Appeals Are Common Except For Variations In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noted That There Is A Delay Of 95 Days In Filing All The Captioned Appeals. The Assessee Has Filed A Petition Explaining The Reasons For The Delay. After Considering The Submissions And

Section 132ASection 142(1)Section 143(2)Section 153A

restore the matter to the file of the CIT(A) with a direction to re-examine the issue afresh after providing due opportunity of being heard to the assessee. 8. Since the facts and issues in the other connected appeals (ITA Nos. 279 to 282/Patna/2025) for assessment years

Aarif Ali, Siwan vs. Ac/DCIT, Central Circle, Muzaffarpur

ITA 278/PAT/2025[2013-14]Status: DisposedITAT Patna16 Oct 2025AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.278 To 283/Pat/2025 Assessment Years: 2013-14 To 2018-19 Aarif Ali……………………………….………. …………………....Appellant Son Of Khush Mohammad, Resident Of Village: Sallahpur, P.O Dindayalpur, Ps: G.B Nagar Darwara, Dist: Siwan, Bihar, Pin-841506. [Pan: Bxfpa9056H] Vs. Acit/Dcit, Muzaffarpur....…..……………..………………….…..... Respondent Appearances By: None (Adjournment Petition Filed) Appeared On Behalf Of The Appellant. Md. Shadab Ahmed, Cir(Dr), Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 16, 2025 आदेश / Order Per Bench: All These Six Appeals In Ita Nos. 278 To 283/Patna/2025 Have Been Filed By The Same Assessee For Assessment Years 2013–14 To 2018– 19, Respectively. Since The Issues Involved In All These Appeals Are Common Except For Variations In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noted That There Is A Delay Of 95 Days In Filing All The Captioned Appeals. The Assessee Has Filed A Petition Explaining The Reasons For The Delay. After Considering The Submissions And

Section 132ASection 142(1)Section 143(2)Section 153A

restore the matter to the file of the CIT(A) with a direction to re-examine the issue afresh after providing due opportunity of being heard to the assessee. 8. Since the facts and issues in the other connected appeals (ITA Nos. 279 to 282/Patna/2025) for assessment years

Deputy Commissioner of Income Tax, Central Circel-4, Surat vs. Bhartiben Bholabhai Radadiya, Surat

In the result, addition u/s 69A is set aside to the file of AO and addition of income from house property as business income is dismissed

ITA 980/SRT/2024[2021-22]Status: DisposedITAT Surat16 Oct 2025AY 2021-22

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.966/Srt/2024 Assessment Year: 2021-22 (Hybrid Hearing) Dy. Commissioner Of Income Shri Mehul Vinubhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, 101, Mangal Deep Apartment, Vs. Aaykar Bhawan, Majura Gate, Kapodara Road, Om Nagar, Parvat Surat-395 001 Patia, Surat-395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ajgpr 7928 B (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.970/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Ankit Bholabhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, Plot No.07, Adarsh Society, Nr. Vs. Aaykar Bhawan, Majura Gate, Gokulam Diary, Athwalines, Surat- Surat-395 001 395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aztpr 2029 N (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.971/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Parshottambhai Bachubhai बनाम/ Tax, Central Circle – 4, Surat, Radadiya Vs. Room No.508, Aaykar 41/42 Om Nagar Society, Nr Puna Bhawan, Majura Gate, Surat- Octroi Naka Parvat Patiya, Surat- 395 001 395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acxpr 3605 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.973/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Rahulkumar Vinubhai बनाम/ Tax, Central Circle – 4, Surat Radadiya Vs. Room No.508, Aaykar 45, Saifee Co-Op. Housing Society

Section 143(3)Section 250

preconceived conclusions. Therefore, to preserve fairness, transparency and credibility of the process, it is imperative that the AO provides the assessee with full opportunity of being heard, discloses all material proposed to be relied upon, allows effective rebuttal and passes a reasoned, objective and speaking order. Any departure from these ... matter is restored to the file of the AO for fresh order in accordance with law after granting adequate and reasonable opportunity of being heard to the appellant. Needless to state, the assessee shall co-operate with the AO as and when called for and furnish ITA Nos.966

Deputy Commissioner of Income Tax, Central Circle- 4, Surat vs. Ankur Bholabhai Radadiya, Surat

In the result, addition u/s 69A is set aside to the file of AO and addition of income from house property as business income is dismissed

ITA 979/SRT/2024[2021-22]Status: DisposedITAT Surat16 Oct 2025AY 2021-22

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.966/Srt/2024 Assessment Year: 2021-22 (Hybrid Hearing) Dy. Commissioner Of Income Shri Mehul Vinubhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, 101, Mangal Deep Apartment, Vs. Aaykar Bhawan, Majura Gate, Kapodara Road, Om Nagar, Parvat Surat-395 001 Patia, Surat-395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ajgpr 7928 B (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.970/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Ankit Bholabhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, Plot No.07, Adarsh Society, Nr. Vs. Aaykar Bhawan, Majura Gate, Gokulam Diary, Athwalines, Surat- Surat-395 001 395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aztpr 2029 N (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.971/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Parshottambhai Bachubhai बनाम/ Tax, Central Circle – 4, Surat, Radadiya Vs. Room No.508, Aaykar 41/42 Om Nagar Society, Nr Puna Bhawan, Majura Gate, Surat- Octroi Naka Parvat Patiya, Surat- 395 001 395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acxpr 3605 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.973/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Rahulkumar Vinubhai बनाम/ Tax, Central Circle – 4, Surat Radadiya Vs. Room No.508, Aaykar 45, Saifee Co-Op. Housing Society

Section 143(3)Section 250

preconceived conclusions. Therefore, to preserve fairness, transparency and credibility of the process, it is imperative that the AO provides the assessee with full opportunity of being heard, discloses all material proposed to be relied upon, allows effective rebuttal and passes a reasoned, objective and speaking order. Any departure from these ... matter is restored to the file of the AO for fresh order in accordance with law after granting adequate and reasonable opportunity of being heard to the appellant. Needless to state, the assessee shall co-operate with the AO as and when called for and furnish ITA Nos.966

Deputy Commissioner of Income Tax, Central Circle 4, Surat vs. Kishorbhai Manubhai Radadiya, Surat

In the result, addition u/s 69A is set aside to the file of AO and addition of income from house property as business income is dismissed

ITA 978/SRT/2024[2021-22]Status: DisposedITAT Surat16 Oct 2025AY 2021-22

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.966/Srt/2024 Assessment Year: 2021-22 (Hybrid Hearing) Dy. Commissioner Of Income Shri Mehul Vinubhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, 101, Mangal Deep Apartment, Vs. Aaykar Bhawan, Majura Gate, Kapodara Road, Om Nagar, Parvat Surat-395 001 Patia, Surat-395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ajgpr 7928 B (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.970/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Ankit Bholabhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, Plot No.07, Adarsh Society, Nr. Vs. Aaykar Bhawan, Majura Gate, Gokulam Diary, Athwalines, Surat- Surat-395 001 395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aztpr 2029 N (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.971/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Parshottambhai Bachubhai बनाम/ Tax, Central Circle – 4, Surat, Radadiya Vs. Room No.508, Aaykar 41/42 Om Nagar Society, Nr Puna Bhawan, Majura Gate, Surat- Octroi Naka Parvat Patiya, Surat- 395 001 395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acxpr 3605 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.973/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Rahulkumar Vinubhai बनाम/ Tax, Central Circle – 4, Surat Radadiya Vs. Room No.508, Aaykar 45, Saifee Co-Op. Housing Society

Section 143(3)Section 250

preconceived conclusions. Therefore, to preserve fairness, transparency and credibility of the process, it is imperative that the AO provides the assessee with full opportunity of being heard, discloses all material proposed to be relied upon, allows effective rebuttal and passes a reasoned, objective and speaking order. Any departure from these ... matter is restored to the file of the AO for fresh order in accordance with law after granting adequate and reasonable opportunity of being heard to the appellant. Needless to state, the assessee shall co-operate with the AO as and when called for and furnish ITA Nos.966

Deputy Commissioner of Income-Tax, Central Circle -4, Surat vs. Chaturbhai Manubhai Radadiya, Surat

In the result, addition u/s 69A is set aside to the file of AO and addition of income from house property as business income is dismissed

ITA 977/SRT/2024[2021-22]Status: DisposedITAT Surat16 Oct 2025AY 2021-22

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.966/Srt/2024 Assessment Year: 2021-22 (Hybrid Hearing) Dy. Commissioner Of Income Shri Mehul Vinubhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, 101, Mangal Deep Apartment, Vs. Aaykar Bhawan, Majura Gate, Kapodara Road, Om Nagar, Parvat Surat-395 001 Patia, Surat-395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ajgpr 7928 B (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.970/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Ankit Bholabhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, Plot No.07, Adarsh Society, Nr. Vs. Aaykar Bhawan, Majura Gate, Gokulam Diary, Athwalines, Surat- Surat-395 001 395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aztpr 2029 N (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.971/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Parshottambhai Bachubhai बनाम/ Tax, Central Circle – 4, Surat, Radadiya Vs. Room No.508, Aaykar 41/42 Om Nagar Society, Nr Puna Bhawan, Majura Gate, Surat- Octroi Naka Parvat Patiya, Surat- 395 001 395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acxpr 3605 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.973/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Rahulkumar Vinubhai बनाम/ Tax, Central Circle – 4, Surat Radadiya Vs. Room No.508, Aaykar 45, Saifee Co-Op. Housing Society

Section 143(3)Section 250

preconceived conclusions. Therefore, to preserve fairness, transparency and credibility of the process, it is imperative that the AO provides the assessee with full opportunity of being heard, discloses all material proposed to be relied upon, allows effective rebuttal and passes a reasoned, objective and speaking order. Any departure from these ... matter is restored to the file of the AO for fresh order in accordance with law after granting adequate and reasonable opportunity of being heard to the appellant. Needless to state, the assessee shall co-operate with the AO as and when called for and furnish ITA Nos.966

Deputy Commissioner of Income-Tax, Central Circle, -4, Surat vs. Vipulkumar Manubhai Radadiya, Surat

In the result, addition u/s 69A is set aside to the file of AO and addition of income from house property as business income is dismissed

ITA 974/SRT/2024[2021-22]Status: DisposedITAT Surat16 Oct 2025AY 2021-22

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.966/Srt/2024 Assessment Year: 2021-22 (Hybrid Hearing) Dy. Commissioner Of Income Shri Mehul Vinubhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, 101, Mangal Deep Apartment, Vs. Aaykar Bhawan, Majura Gate, Kapodara Road, Om Nagar, Parvat Surat-395 001 Patia, Surat-395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ajgpr 7928 B (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.970/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Ankit Bholabhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, Plot No.07, Adarsh Society, Nr. Vs. Aaykar Bhawan, Majura Gate, Gokulam Diary, Athwalines, Surat- Surat-395 001 395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aztpr 2029 N (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.971/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Parshottambhai Bachubhai बनाम/ Tax, Central Circle – 4, Surat, Radadiya Vs. Room No.508, Aaykar 41/42 Om Nagar Society, Nr Puna Bhawan, Majura Gate, Surat- Octroi Naka Parvat Patiya, Surat- 395 001 395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acxpr 3605 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.973/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Rahulkumar Vinubhai बनाम/ Tax, Central Circle – 4, Surat Radadiya Vs. Room No.508, Aaykar 45, Saifee Co-Op. Housing Society

Section 143(3)Section 250

preconceived conclusions. Therefore, to preserve fairness, transparency and credibility of the process, it is imperative that the AO provides the assessee with full opportunity of being heard, discloses all material proposed to be relied upon, allows effective rebuttal and passes a reasoned, objective and speaking order. Any departure from these ... matter is restored to the file of the AO for fresh order in accordance with law after granting adequate and reasonable opportunity of being heard to the appellant. Needless to state, the assessee shall co-operate with the AO as and when called for and furnish ITA Nos.966

Deputy Commissioner of Income-Tax, Central Circle-4, Surat vs. Rahulkumar Vinubhai Radadiya, Surat

In the result, addition u/s 69A is set aside to the file of AO and addition of income from house property as business income is dismissed

ITA 973/SRT/2024[2021-22]Status: DisposedITAT Surat16 Oct 2025AY 2021-22

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.966/Srt/2024 Assessment Year: 2021-22 (Hybrid Hearing) Dy. Commissioner Of Income Shri Mehul Vinubhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, 101, Mangal Deep Apartment, Vs. Aaykar Bhawan, Majura Gate, Kapodara Road, Om Nagar, Parvat Surat-395 001 Patia, Surat-395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ajgpr 7928 B (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.970/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Ankit Bholabhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, Plot No.07, Adarsh Society, Nr. Vs. Aaykar Bhawan, Majura Gate, Gokulam Diary, Athwalines, Surat- Surat-395 001 395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aztpr 2029 N (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.971/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Parshottambhai Bachubhai बनाम/ Tax, Central Circle – 4, Surat, Radadiya Vs. Room No.508, Aaykar 41/42 Om Nagar Society, Nr Puna Bhawan, Majura Gate, Surat- Octroi Naka Parvat Patiya, Surat- 395 001 395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acxpr 3605 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.973/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Rahulkumar Vinubhai बनाम/ Tax, Central Circle – 4, Surat Radadiya Vs. Room No.508, Aaykar 45, Saifee Co-Op. Housing Society

Section 143(3)Section 250

preconceived conclusions. Therefore, to preserve fairness, transparency and credibility of the process, it is imperative that the AO provides the assessee with full opportunity of being heard, discloses all material proposed to be relied upon, allows effective rebuttal and passes a reasoned, objective and speaking order. Any departure from these ... matter is restored to the file of the AO for fresh order in accordance with law after granting adequate and reasonable opportunity of being heard to the appellant. Needless to state, the assessee shall co-operate with the AO as and when called for and furnish ITA Nos.966

Deputy Commissioner of Income-Tax, Central Circle-4, Surat vs. Parshottambhai Bachubhai Radadia, Surat

In the result, addition u/s 69A is set aside to the file of AO and addition of income from house property as business income is dismissed

ITA 971/SRT/2024[2021-22]Status: DisposedITAT Surat16 Oct 2025AY 2021-22

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.966/Srt/2024 Assessment Year: 2021-22 (Hybrid Hearing) Dy. Commissioner Of Income Shri Mehul Vinubhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, 101, Mangal Deep Apartment, Vs. Aaykar Bhawan, Majura Gate, Kapodara Road, Om Nagar, Parvat Surat-395 001 Patia, Surat-395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ajgpr 7928 B (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.970/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Ankit Bholabhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, Plot No.07, Adarsh Society, Nr. Vs. Aaykar Bhawan, Majura Gate, Gokulam Diary, Athwalines, Surat- Surat-395 001 395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aztpr 2029 N (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.971/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Parshottambhai Bachubhai बनाम/ Tax, Central Circle – 4, Surat, Radadiya Vs. Room No.508, Aaykar 41/42 Om Nagar Society, Nr Puna Bhawan, Majura Gate, Surat- Octroi Naka Parvat Patiya, Surat- 395 001 395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acxpr 3605 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.973/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Rahulkumar Vinubhai बनाम/ Tax, Central Circle – 4, Surat Radadiya Vs. Room No.508, Aaykar 45, Saifee Co-Op. Housing Society

Section 143(3)Section 250

preconceived conclusions. Therefore, to preserve fairness, transparency and credibility of the process, it is imperative that the AO provides the assessee with full opportunity of being heard, discloses all material proposed to be relied upon, allows effective rebuttal and passes a reasoned, objective and speaking order. Any departure from these ... matter is restored to the file of the AO for fresh order in accordance with law after granting adequate and reasonable opportunity of being heard to the appellant. Needless to state, the assessee shall co-operate with the AO as and when called for and furnish ITA Nos.966

Deputy Commissioner of Income-Tax, Central Circle-4, Surat vs. Ankit Bholabhai Radadiya, Surat

In the result, addition u/s 69A is set aside to the file of AO and addition of income from house property as business income is dismissed

ITA 970/SRT/2024[2021-22]Status: DisposedITAT Surat16 Oct 2025AY 2021-22

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.966/Srt/2024 Assessment Year: 2021-22 (Hybrid Hearing) Dy. Commissioner Of Income Shri Mehul Vinubhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, 101, Mangal Deep Apartment, Vs. Aaykar Bhawan, Majura Gate, Kapodara Road, Om Nagar, Parvat Surat-395 001 Patia, Surat-395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ajgpr 7928 B (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.970/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Ankit Bholabhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, Plot No.07, Adarsh Society, Nr. Vs. Aaykar Bhawan, Majura Gate, Gokulam Diary, Athwalines, Surat- Surat-395 001 395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aztpr 2029 N (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.971/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Parshottambhai Bachubhai बनाम/ Tax, Central Circle – 4, Surat, Radadiya Vs. Room No.508, Aaykar 41/42 Om Nagar Society, Nr Puna Bhawan, Majura Gate, Surat- Octroi Naka Parvat Patiya, Surat- 395 001 395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acxpr 3605 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.973/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Rahulkumar Vinubhai बनाम/ Tax, Central Circle – 4, Surat Radadiya Vs. Room No.508, Aaykar 45, Saifee Co-Op. Housing Society

Section 143(3)Section 250

preconceived conclusions. Therefore, to preserve fairness, transparency and credibility of the process, it is imperative that the AO provides the assessee with full opportunity of being heard, discloses all material proposed to be relied upon, allows effective rebuttal and passes a reasoned, objective and speaking order. Any departure from these ... matter is restored to the file of the AO for fresh order in accordance with law after granting adequate and reasonable opportunity of being heard to the appellant. Needless to state, the assessee shall co-operate with the AO as and when called for and furnish ITA Nos.966

Ravi Meemrot, Deputy Commissioner of Income-Tax, Central Circle-4, Surat vs. Mehul Vinubhai Radadiya, Surat

In the result, addition u/s 69A is set aside to the file of AO and addition of income from house property as business income is dismissed

ITA 966/SRT/2024[2021-22]Status: DisposedITAT Surat16 Oct 2025AY 2021-22

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.966/Srt/2024 Assessment Year: 2021-22 (Hybrid Hearing) Dy. Commissioner Of Income Shri Mehul Vinubhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, 101, Mangal Deep Apartment, Vs. Aaykar Bhawan, Majura Gate, Kapodara Road, Om Nagar, Parvat Surat-395 001 Patia, Surat-395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ajgpr 7928 B (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.970/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Ankit Bholabhai Radadiya बनाम/ Tax, Central Circle – 4, Surat, Plot No.07, Adarsh Society, Nr. Vs. Aaykar Bhawan, Majura Gate, Gokulam Diary, Athwalines, Surat- Surat-395 001 395 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aztpr 2029 N (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.971/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Parshottambhai Bachubhai बनाम/ Tax, Central Circle – 4, Surat, Radadiya Vs. Room No.508, Aaykar 41/42 Om Nagar Society, Nr Puna Bhawan, Majura Gate, Surat- Octroi Naka Parvat Patiya, Surat- 395 001 395 010 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Acxpr 3605 H (अपीलाथ"/Appellant) (""थ" /Respondent) आयकर अपील सं./Ita No.973/Srt/2024 Assessment Year: 2021-22 Dy. Commissioner Of Income Shri Rahulkumar Vinubhai बनाम/ Tax, Central Circle – 4, Surat Radadiya Vs. Room No.508, Aaykar 45, Saifee Co-Op. Housing Society

Section 143(3)Section 250

preconceived conclusions. Therefore, to preserve fairness, transparency and credibility of the process, it is imperative that the AO provides the assessee with full opportunity of being heard, discloses all material proposed to be relied upon, allows effective rebuttal and passes a reasoned, objective and speaking order. Any departure from these ... matter is restored to the file of the AO for fresh order in accordance with law after granting adequate and reasonable opportunity of being heard to the appellant. Needless to state, the assessee shall co-operate with the AO as and when called for and furnish ITA Nos.966