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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

Ramagopal Varma Ramaraju, Hyderabad vs. ITO, Interenational Taxation-2, Hyderabad

In the result, the appeal filed by the assessee arising from the assessment order passed u/sec

ITA 1302/HYD/2025[2015-16]Status: DisposedITAT Hyderabad15 Oct 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /It(It)A No.507/Hyd/2025 & Ita.No.1302/Hyd./2025 िनधा"रण वष"/Assessment Year 2015-2016 Ramgopal Varma The Income Tax Officer Ramaraju, Hyderabad. Vs. [Int.Taxn]-2, Hyderabad Pin – 500 060. Telangana. Pin - 500 004. Telangana. Pan Arppr7316E (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Sri S Rama Rao, Advocate Dr. Narendra Kumar Naik, Cit-Dr राज" व "ारा/Revenue By: & Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 15.10.2025 घोषणा की तारीख/Pronouncement: 15.10.2025 आदेश/Order Per Vijay Pal Rao:

For Appellant: Sri S Rama Rao, AdvocateFor Respondent: And Dr. Sachin Kumar, Sr. AR
Section 139(1)Section 144C(1)Section 144C(5)Section 147Section 148Section 69ASection 69C

assessee is at liberty to raise any other objections before the DRP. Needless to say, the assessee be given a proper opportunity of being heard before passing the order by the DRP and 10 ITA.Nos.507 & 1302/Hyd./2025 consequential Final Assessment Order by the Assessing Officer. 10. In the result

Sri Shyambaba Electronic Pvt Ltd, Hyderabad vs. DCIT., Circle-3(1), Hyderabad

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

ITA 453/HYD/2024[2021-22]Status: DisposedITAT Hyderabad15 Oct 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.453/Hyd/2024 िनधा"रण वष"/Assessment Year 2021-2022 Sri Shyambaba Electronic The Dcit, Pvt. Ltd., Hyderabad. Vs. Circle-3(1), Pin – 500 012. Telangana. Hyderabad. Pan Aaxcs1651F (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Ca A Srinivas राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 07.10.2025 घोषणा की तारीख/Pronouncement: 15.10.2025 आदेश/Order Per Vijay Pal Rao: This Appeal By The Assessee Is Directed Against The Order Dated 11.03.2024 Of The Learned Cit(A)-National Faceless Appeal Centre [In Short “Nfac], Delhi, For The Assessment Year 2021-2022. 2

For Appellant: CA A SrinivasFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 143(3)

ignoring the facts in case. 7 ITA.No.453/Hyd./2024 5. That the Learned A.O, has erred in passing the order without providing sufficient opportunity of being heard as well as opportunity of cross examining the persons those who have not submitted responses to the notices issued

M.N. Chickkanna Chettiar Trust, Tiruppur vs. ACIT (Exemptions), Coimbatore

In the result the appeal of the assessee for the A

ITA 1568/CHNY/2025[2020-21]Status: DisposedITAT Chennai15 Oct 2025AY 2020-21

Bench: Shri Aby T Varkey & Shri S. R. Raghunatha

For Appellant: Shri. T.Banusekar, AdvocateFor Respondent: Ms. R. Kavitha, Addl. C.I.T
Section 11Section 119(2)(b)Section 12ASection 143(1)Section 234BSection 250

Grounds 3. For that the Commissioner of Income Tax (Appeals) erred in dismissing the appellant’s case without providing the appellant a proper opportunity of being heard. 4. For that the Commissioner of Income Tax (Appeals) failed to appreciate that the intimation issued u/s.143(1) of the Income

Ucal Limited, Chennai vs. PCIT, Chennai-3, Chennai

ITA 1018/CHNY/2025[2020-21]Status: DisposedITAT Chennai15 Oct 2025AY 2020-21

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. S. Sridhar, Advocate &For Respondent: Shri. C.N. Bipin, C.I.T
Section 143(3)Section 263Section 36(1)(va)Section 37

aside to the file of the Assessing Officer to examine the above issues in detail and complete the assessment after affording reasonable opportunity of being heard to the Assessee.” 6. Aggrieved by the said order, the assessee is before us in challenging the revision order dated 24.03.2025 passed in terms

Jayshree Devi Ramji Gupta, Mumbai vs. ADIT, Mumbai

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

ITA 6048/MUM/2025[2018-19]Status: DisposedITAT Mumbai15 Oct 2025AY 2018-19

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Shashank Mehta, A/RFor Respondent: Ms. Kavitha Kaushik, Sr. D/R
Section 143(1)Section 40A(3)

directed to examine the same and decide the issue afresh after affording reasonable and adequate opportunity of being heard to the assessee. 8. The next quarrel relates to the non-granting of the credit of tax collected at source as the same was collected in the name of the husband

Jayshree Devi Ramji Gupta, Mumbai vs. ADIT, Mumbai

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

ITA 6047/MUM/2025[2019-20]Status: DisposedITAT Mumbai15 Oct 2025AY 2019-20

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: Shri Shashank Mehta, A/RFor Respondent: Ms. Kavitha Kaushik, Sr. D/R
Section 143(1)Section 40A(3)

directed to examine the same and decide the issue afresh after affording reasonable and adequate opportunity of being heard to the assessee. 8. The next quarrel relates to the non-granting of the credit of tax collected at source as the same was collected in the name of the husband

Wazeera Saleh Mithiborwala, Mumbai vs. DCIT Circle 35(3) Mumbai, Mumbai

In the result, the appeal by the assessee is allowed

ITA 484/MUM/2025[2014-2015]Status: DisposedITAT Mumbai15 Oct 2025AY 2014-2015

Bench: Shri Sandeep Singh Karhailshri Prabhash Shankarwazeera Saleh Mithiborwala, 1001/1002 Natura, Tapovan, Co-Op. Housing Society, J.K. Mehta Marg, Santacruz West, Mumbai - 400054 ............... Appellant Pan: Acgpm5141G V/S Deputy Commissioner Of Income Tax, Circle – 35(3), ……………… Respondent Mumbai

For Appellant: Shri Nishit Gandhi, AdvocateFor Respondent: Shri Swapnil Choudhary, Sr. DR
Section 10(38)Section 143Section 143(2)Section 143(3)Section 144Section 147Section 148Section 250Section 68

failed to appreciate that: (a) The Order is passed by him without affording any fair, reasonable and sufficient opportunity of being heard to the Appellant; (b) The Assessee (Appellant) was not aware of the transfer of the appeal to the CIT(A), NFAC and therefore no submissions could

Sunil Gangadhar Karve, Mumbai vs. Dy CIT Circle 16(3), Mumbai

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

ITA 2619/MUM/2025[2021-22]Status: DisposedITAT Mumbai15 Oct 2025AY 2021-22

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhan

Section 143(1)Section 23Section 250Section 71B

property" assessed in the intimation passed u/s.143(1) of the Income-tax Act, 1961 without appreciating that no reason was provided nor any opportunity of being heard was given to the assessee before issuing the intimation. 4 The learned Commissioner of Income-tax (A) erred in confirming the action

Mukul Hasteer, Karnal vs. ITO Ward-1, Karnal

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

ITA 96/DEL/2025[2018-19]Status: DisposedITAT Delhi15 Oct 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 147Section 148Section 234A

Authority wrongly & illegally dismissed the appeal without considering the written submissions in an arbitrary manner and that too without allowing proper and reasonable opportunity of being heard after issuing only single notice of hearing without application of mind in a mechanical manner in an ex-parte order. 1 Mukul Hasteer ... Based on the specific information, the case of the assessee was reopened under section 147 of the Income Tax Act, 1961 (‘Act’). Various opportunities of being heard to ensure compliance to the show-cause notices were provided by the Ld. AO. However, only part-compliance was made by the assessee

Delhi Duty Free Services Private Limted, Delhi vs. DCIT, Central Circle-13, New Delhi

In the result, appeals of Revenue in decided as follows:

ITA 69/DEL/2025[2020-21]Status: DisposedITAT Delhi15 Oct 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Ankit Agarwal, CAFor Respondent: Shri Rajesh Mahajan, Sr. DR
Section 135Section 80Section 80G

from books as compared to Form 26 AS be set aside to the file of CIT(A) for fresh adjudication after allowing adequate opportunity of being heard to the assessee. The assessee is also directed to provide necessary information /documents as required by the authorities. Ground is allowed for statistical

Delhi Duty Free Services Private Limited, Delhi vs. DCIT, Central Circle-13, Delhi

In the result, appeals of Revenue in decided as follows:

ITA 68/DEL/2025[2018-19]Status: DisposedITAT Delhi15 Oct 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Ankit Agarwal, CAFor Respondent: Shri Rajesh Mahajan, Sr. DR
Section 135Section 80Section 80G

from books as compared to Form 26 AS be set aside to the file of CIT(A) for fresh adjudication after allowing adequate opportunity of being heard to the assessee. The assessee is also directed to provide necessary information /documents as required by the authorities. Ground is allowed for statistical

Delhi Duty Free Services Private Limited, Delhi vs. DCIT, Circle-13, Delhi

In the result, appeals of Revenue in decided as follows:

ITA 67/DEL/2025[2017-18]Status: DisposedITAT Delhi15 Oct 2025AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Ankit Agarwal, CAFor Respondent: Shri Rajesh Mahajan, Sr. DR
Section 135Section 80Section 80G

from books as compared to Form 26 AS be set aside to the file of CIT(A) for fresh adjudication after allowing adequate opportunity of being heard to the assessee. The assessee is also directed to provide necessary information /documents as required by the authorities. Ground is allowed for statistical

Gulshan Kumar, Gurgaon vs. ITO Ward-1(3), Gurgaon

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

ITA 2242/DEL/2025[2020-21]Status: DisposedITAT Delhi15 Oct 2025AY 2020-21

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 194HSection 250Section 40Section 44ASection 69A

case, NFAC has erred both on facts and in law in passing the order without giving assessee a proper and adequate opportunity of being heard is clear violation of principle of natural justice. (ii) That the non-appearance before the NFAC was on account of reasons beyond the control ... Income Tax Act, 1961 (‘Act’). Before, the Ld. Assessing Officer (‘AO’), no effective compliance was made by the assessee though many opportunities of being heard were provided by the Ld. AO. Aggrieved, the assessee filed appeal before the Ld. CIT(A), who dismissed the appeal, ex-parte, holding as under

Honeywell Exim Private Limited, New Delhi vs. ACIT, Circle-10(1), Delhi

In the result the appeal of the assessee is allowed”

ITA 6033/DEL/2024[2015-16]Status: DisposedITAT Delhi15 Oct 2025AY 2015-16

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2015-16 Honeywell Exim Private Vs. Acit, Limited, House No. 121, Circle-10(1), A Pkt., B-04, Keshavpuram. Delhi New Delhi-1100 35 1100 07 Pan: Aadch3719B (Appellant) (Respondent)

For Appellant: Shri Ved Jain, Adv. , Shri Pawan Garg and Ms. Ishika Dua, CAsFor Respondent: Shri Sanjeev Kaushal, CIT (DR)
Section 139(1)Section 142(1)Section 144Section 147Section 148Section 148ASection 151Section 250

case, the order passed by the learned CIT(A), NFAC is bad in law having been passed exparte without providing the assessee reasonable opportunity of being heard in clear violation of the principles of natural justice. 3. On the facts and circumstances of the case, the CIT(A), NFAC

Assimilate Solutions India Pvt. Ltd., Delhi vs. DCIT Circle, 1(1), Delhi

In the result, the ground raised by the assessee in this regard is dismissed

ITA 5357/DEL/2024[2021-22]Status: DisposedITAT Delhi15 Oct 2025AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Vimal Kumarassimilate Solutions India Private Limited, Vs. Dcit/Acit, C/O Sanjiv Sapra & Associates Llp, Circle 1 (1), Chartered Accountants, New Delhi. C – 763, New Friends Colony, New Delhi – 110 025. (Pan :Aakca4501H) (Appellant) (Respondent) Assessee By : Shri Sanjiv Sapra, Ar Revenue By : Shri Dharam Veer Singh, Cit Dr Date Of Hearing : 30.07.2025 Date Of Order : 15.10.2025 Order Per S. Rifaur Rahman: 1. The Assessee Has Filed Appeal Against Assessment Order Dated 31.12.2015 Passed By The Assessment Unit, Income Tax Department Under Section 143(3) Read With Section 144C(13)R.W.S. 144B Of The Income-Tax Act, 1961 (For Short ‘The Act”) For Assessment Year 2021-22 Pursuant To The Directions Of The Dispute Resolution Panel U/S 144C(5) Of The Act. 2. M/S. Assimilate Solutions India Private Limited, The Assessee Was Incorporated On 19.04,2012 & Is Engaged In The Business Of Providing

For Appellant: Shri Sanjiv Sapra, ARFor Respondent: Shri Dharam Veer Singh, CIT DR
Section 143(2)Section 143(3)Section 144C(13)Section 144C(5)

inclined to remit this issue back to the file of AO to verify the above issues as per law after giving an opportunity of being heard to the assessee. In the result, ground raised by the assessee is allowed for statistical purpose. 18. In the result appeal, appeal filed

Mannohar Lal Hira Lal Ltd, Ghaziabad vs. ITO, Ward- 2(1)(4), Ghaziabad

In the result, the appeal of the assessee is allowed

ITA 2663/DEL/2022[2017-18]Status: DisposedITAT Delhi15 Oct 2025AY 2017-18

Bench: Shri Mahavir Singh, Hon’Bleasstt. Year : 2017-18 Mannohar Lal Hira Lal Ltd. Vs. Ito, Ward 2(1)(4) C/O Praveen K. Agarwal & Ghaziabad Associates Cgo Complex-1 D-17 Third Floor Ghaziabad-201001 Rdc Raj Nagar Ghaziabad Uttar Pradesh-201001 (Pan: Aabcm1295R) (Appellant) (Respondent) Appellant By : Shri Sidhantgoyal Ca Respondent By: Shri Ashok Kumar Pandey, Sr. Dr.

For Appellant: Shri SidhantGoyal CAFor Respondent: Shri Ashok Kumar Pandey, Sr. DR
Section 143(2)

circumstances of the case and in law the AO has made an entirely new addition in the final assessment order without an opportunity of being heard to the assessee in the show cause notice. Thus being violative of principles of natural justice, the proceeding are null and void.” 4. During

Shri Mahaveer Charitable Trust, Allahabad vs. ITO(Exemption), Allahabad

In the result, the appeal of the assessee is partly allowed

ITA 181/ALLD/2024[2013-14]Status: DisposedITAT Allahabad14 Oct 2025AY 2013-14

Bench: Sh. Subhash Malguria & Sh. Nikhil Choudharya.Y. 2013-14 Shri Mahaveer Charitable Trust, Vs Income Tax Officer 46, Rajendra Nagar, Baluaghat, (Exemption), Allahabad Allahabad-211003, U.P. Pan: Aahts9123K (Appellant) (Respondent) Assessee By: Dr. Pawan Jaiswal & Sh. Ajit Kumar, Advocates Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 22.07.2025 Date Of 14.10.2025 Pronouncement: O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit, Nfac Dated 28.09.2024, Wherein The Ld. Cit(A) Has Dismissed The Appeal Of The Assessee That Was Filed Against The Orders Of The Income Tax Officer (Exemption), Allahabad Dated 30.03.2018. The Grounds Of Appeal Are As Under: - “1. Because The Impugned Order Of The Ld. Cit(A) Dated 28.09.2024 Affirming The Addition Of Rs. 1,97,69,650/- On Account Of Donation Received & Rejection Of The Submissions Of The Appellant That Appeal Proceedings Pending Against The Order Passed Under Section 143(3) Dated 30.03.2016 Are Infructuous Is Absolutely Illegal & Against The Principles Of Law. 2. Because The Hon'Ble Supreme Court In The Case Of Cit V. Alagendran Finance Ltd. [27.07.2007] Had Observed That When An Order Of Assessment Is Reopened, The Previous Assessment Will Be Held To Be Set Aside & The Whole Proceedings Would Start Afresh & In The Case In Hands The Assessment Order Dated 30.03.2016 Has Been Set-Aside By The Then Incumbent Ld. Cit(E); That Is To Say That No Assessment Existed On The Date When Order Dated 28.02.2018 Under Section 263 Of The Act Was Passed By The Then Incumbent Cit(E). 3. Because Section 263 Of The Act Grants Power To The Jurisdictional Commissioner To Direct For Revision Of Orders & Reads As Under (Relevant Statute Quoted):

For Appellant: Dr. Pawan Jaiswal & Sh. Ajit Kumar, AdvocatesFor Respondent: Sh. A.K. Singh, Sr. DR
Section 143(3)Section 263

erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the appellant an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify

Rajeev Kumar, Patna vs. ITO, Ward- 6 (4), Patna

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

ITA 303/PAT/2025[2016-17]Status: DisposedITAT Patna14 Oct 2025AY 2016-17

Bench: Shri Duvvuru Rl Reddy(Kz) Assessment Year : 2016-17 Rajeev Kumar, S/O.Late Krishna Vs. Ito, Ward 6(4), Patna Chand Gupta, Govindpur, Fatuha, Patna Pan/Gir No. Agypk 0699 K (Appellant) .. ( Respondent) Assessee By : Shri Rakesh Kumar, Adv Revenue By : Shri Ashwani Kumar Singhal, Jcit Date Of Hearing : 28/08/2025 Date Of Pronouncement : 14/10/2025 O R D E R The Present Appeal Is Directed At The Instance Of Assessee Against The Order Of Ld. Addl/Jcit-2, Ahmedabad Dated 20.2.2025 In Appeal No.Cit(A), Patna -2/10156/2019-20 Passed For Assessment Year 2016-17. 2. The Appeal Is Time Barred By 58 Days. The Assessee Has Filed Condonation Petition Supported With Affidavit Stating That The Order Of The Ld Cit(A) Is Dated 20.2.2025 & The Appeal Was Filed In The E-Portal On 20.2.2025, Therefore, There Was No Delay In Filing The Appeal. However, If This Appeal Is Treated As A Belated Appeal By Counting The Limitation From The Date & Uploading The Order On The E-Portal, The Assessee Prayed For Condoning

For Appellant: Shri Rakesh Kumar, AdvFor Respondent: Shri Ashwani Kumar Singhal, JCIT
Section 144

principle of natural justice, remit the matter back to the file of the ld CIT(A) with a direction to provide one more opportunity of being heard to the assessee. At the same breath, I also hereby caution the assessee to promptly co-operate with the proceedings before

Sahaj Agro Farm, Surat, Gujarat vs. Additional, Joint, Deputy, Assistant Commissioner of Income Tax, ITO, Delhi

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

ITA 23/SRT/2024[2018-19]Status: DisposedITAT Surat14 Oct 2025AY 2018-19

Bench: Shri Diesh Mohan Sinha & Shri Bijayananda Pruseth

For Appellant: Shri Rajiv N Shah ARFor Respondent: Shri Ajay Uke, Ld. Sr. DR
Section 143(1)Section 143(2)Section 250

order which is a mandatory requirement for faceless appeal scheme, Your Appellant prays to set aside the said order and that a fresh opportunity of being heard and to furnish documentary evidences must be provided and that the addition made must be deleted in totality. 2) That on the fact

Manilal Bhanabhai Gohil Education Trust, Na vs. Arivs.ITO(Exemption), Surat

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

ITA 1079/SRT/2024[2022-23]Status: DisposedITAT Surat14 Oct 2025AY 2022-23

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1079/Srt/2024 Assessment Year: 2022-23 (Hybrid Hearing) Manilal Bhanabhai Gohil Income Tax Officer (Exemption), बनाम/ Education Trust, Surat, Ayakar Bhawan, Majura Vs. Post Box No.68, Nr. Ramaben Gate, Surat-395 001 Hospital, Bodali, Navsari- 396 445 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aabtm 9517 D (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri Kamlesh Bhatt, Ca राज" की ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 30/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 14/10/2025

Section 11Section 12ASection 139(1)Section 143(1)Section 250Section 80I

directed to verify the Income and Expenditure account and tax only the surplus amount after granting adequate and reasonable opportunity of being heard to the appellant. The appellant is also directed all necessary details as required by the AO. The ground is allowed for statistical purposes. 8. In the result