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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

Ajay Kumar, Saran, Bihar vs. ITO, Chapra

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

ITA 402/PAT/2024[2017-18]Status: DisposedITAT Patna08 Oct 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 133(6)Section 142(1)Section 144Section 234ASection 250Section 270ASection 271ASection 44ASection 69A

considered that the request of the assessee to set aside 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

M/S. Nitaben Bharatkumar Parekh, Surat vs. Addl/JCIT (A)-2, Chennai

In the result, the delay in filing the appeal is condoned, and the appeal is allowed for statistical purposes in the terms indicated hereinabove

ITA 731/SRT/2025[2017-18]Status: HeardITAT Surat08 Oct 2025AY 2017-18

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2017-2018 M/S Nitaben Bharatkumar Add/Jcit(A)-2, Chennai, Parekh, Surat. 33 Royal Bunglows, Opp. Laxmi Vs. Bunglows Vesu Surat-395007. Pan No. Adlpp 7174 Q Appellant Respondent

For Appellant: Mr. Ajay Uke, Sr. DRFor Respondent: Mr. Ronak Parekh, AR
Section 115BSection 5Section 69A

file for de novo adjudication after considering the submissions and evidences, if any, furnished by the assessee. The CIT(A) shall provide adequate opportunity of being heard and shall pass a reasoned order in accordance with law. The relevant ground of the appeal of the assessee is accordingly allowed

Dipak Chandrakantbhai Ughadpaga, Surat vs. ITO, Ward 1(3)(6), Surat

In the result, the appeal of the assessee is allowed for statistical purposes, subject to the payment of cost as directed hereinabove

ITA 644/SRT/2025[2017-18]Status: HeardITAT Surat08 Oct 2025AY 2017-18

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2017-2018 Dipak Chandrakantbhai Ito Ward 1(3)(6), Ughadpaga, Room No. 303, 3Rd Floor, Income 23, Premji Nagar, Adajan Road, Vs. Tax Office, Anavil Business Opp. Shital Studio, Nr. Gujarat Centre, Adajan, Gas Circle, Surat-395007. Surat-395009. Pan No. Aaypu 8592 K Appellant Respondent

For Respondent: Mr. Rasesh Shah, CA
Section 115BSection 5Section 69A

well as law on the subject, the ld. CIT(A) has erred in passing ex-parte order without giving reasonable AMD sufficient opportunity of being heard 5. On the facts AMD circumstances of the case as well as law on the subject, the Ld. CIT(A) has erred in dismissing

Shri Pragnesh Lallubhai Patel, Na vs. Arivs.ITO, Ward-4, Navsari

In the result, appeal of the assessee is unadmitted

ITA 940/SRT/2024[2010-11]Status: HeardITAT Surat08 Oct 2025AY 2010-11

Bench: Shri Sandeep Gosain () & Shri Om Prakash Kant () Assessment Year: 2010-2011 Shri Pragnesh Lallubhai Patel, Ito Ward-4, At Butlav, Post Dabhalai, Room No. 203, Swapnalok Soc. Navsari,-396466. Vs. Nr. Kaliawadi Bridge, Navsari, Gujarat-396445. Pan No. Aodpp 0260 N Appellant Respondent

For Appellant: Ms. Namita Patel, Sr. DRFor Respondent: Mr. Rasesh Shah, CA
Section 144Section 147Section 148Section 5Section 69

well as law on the subject, the learned CIT(A) has erred in passing ex-parte order without giving reasonable and sufficient opportunity of being heard. 2. On the facts and circumstances of the case as well as law on the subject, the learned CIT(A) has erred in dismissing

Sree Anantalakshmi Textiles Pvt Ltd, Guntur vs. Income Tax Officer, TDS Ward-1, Eluru

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

ITA 402/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2020-21

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकरअपीलसं./I.T.A.No.402/Viz/2025 (निर्धारणवर्ा/ Assessment Year: 2020-21) Sree Anantalakshmi Textiles (P) Ltd., Vs. Income Tax Officer – Tds Ward-1 C/O. Nsl Textiles Limited Income Tax Office, Kks Towers Engee House, 3Rd Floor, 4Th Line R.R. Pet, Eluru – 534002 Chadramouli Nagar, Guntur – 522007 Andhra Pradesh Andhra Pradesh [Pan:Aadcs1442E] (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri Gvn Hari, Advocate : Dr. Aparna Villuri,Sr.Ar राजस्व का प्रतततितित्व/ Department Represented By सुिवाई समाप्त होिे की ततति/ Date Of Conclusion Of Hearing : 25.09.2025 घोर्णध की तधरीख/Date Of Pronouncement : 08.10.2025

Section 201(1)Section 40

assessee. Needless to say, Page. No 6 I.T.A.No.402/VIZ/2025 Sree Anantalakshmi Textiles (P) Ltd., the assessee shall be given an appropriate opportunity of being heard during the proceedings before the Ld. CIT(A). The Assessee is also directed to cooperate in the proceedings and furnish necessary documents / information as required

Devi Sea Foods Limited, Visakhapatnam vs. Principal Commissioner of Income Tax, Visakhapatnam

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

ITA 316/VIZ/2025[2020-21]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2020-21

Bench: Shri Ravish Sood, Hon’Ble

Section 143(3)Section 145Section 14ASection 263

further submitted that the Ld.Pr.CIT has also not directed the Ld. AO to Page. No7 LT.A.No.316/VIZ/2025 M/s. Devi Sea Foods Limited =* provide opportunity of being heard to the assessee during the remand proceedings. 8. Per contra, Ld. Departmental Representative [hereinafter in short “Ld.DR”] submitted that as per the provisions ... assessment. Ld.Pr.CIT ought not to have given a specific direction by which Ld. AO was directed to complete the assessment, without providing an opportunity of being heard to the assessee. However, since there is no whisper in the order of the Ld.AO regarding the allowability of foreign exchange loss

Deputy Commissioner of Income Tax, Circle 3(1), Visakhapatnam vs. Vizag Re-Bars Private Limited, Visakhapatnam

In the result, the cross objection filed by the assessee is allowed

ITA 428/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam08 Oct 2025AY 2017-18

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.428/Viz/2024 (निर्धारणवर्ा/ Assessment Year: 2017-18) Dy. Cit – Circle – 3(1) Vs. M/S. Vizag Re-Bars Private Limited 35, 50-92-35, Sankara Matam Road Plot No. 1 Ida, Edulapaka Bonangi, Opposite Reliance Fresh Parawada Mandal – 531021 Beside Reliance Fresh, Near By Main Road Andhra Pradesh Madhuranagar, Dwaraka Nagar Visakhapatnam – 530016 [Pan:Aabcv2581M] Andhra Pradesh (अपीलधर्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 10(38)Section 115JSection 143(3)Section 147Section 148Section 148A

approval of specified authority, with respect to the information which suggests that the income chargeable to tax has escaped assessment; (b) provide an opportunity of being heard to the assessee, with the prior approval of specified authority, by serving upon him a notice to show cause within such time

Usha Sharma, Jaipur vs. Income Tax Officer, Jaipur

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

ITA 320/JPR/2025[2012-13]Status: DisposedITAT Jaipur08 Oct 2025AY 2012-13

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

For Appellant: Mrs. Suhani Meharwal, CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR
Section 142(1)Section 147Section 148Section 14ySection 234ASection 234B

assessee that lis between the parties has to be decided on merits so that nobody’s rights could be scuttled down without providing opportunity of being heard to the assessee. Hence, the matter is restored to the file of the AO to decide it afresh by providing one more opportunity

Dai Chand, Kaithal vs. Income Tax Officer, Kaithal

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

ITA 936/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh08 Oct 2025AY 2012-13

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Pulkit Saini, AdvocateFor Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR
Section 144Section 148Section 234ASection 271(1)(c)Section 69Section 69A

income. 5. That the Ld. CIT (Appeals) has erred in law and on facts in confirming the ex-parte addition without granting adequate opportunity of being heard. 6. That the assessment order is null and void as the same is in violation of CBDT circular no.19/2019 mandating

Endocrine and Breast Surgery Foundation, Chandigarh vs. Commissioner of Income Tax Exemptions, Chandigarh

In the result, both the above appeals of the Assessee are dismissed

ITA 245/CHANDI/2025[2025-26]Status: DisposedITAT Chandigarh08 Oct 2025AY 2025-26

Bench: Such Rejection. It Was Also Contended That Such Action Is Violative Of The Principles Of Natural Justice.

For Appellant: Shri S.K. Bhasin and Shri K.B. Sood, CA’sFor Respondent: Shri Manav Bansal, CIT, DR
Section 12ASection 12A(1)(ac)Section 2(15)Section 80G(5)

rejected by the Ld. CIT (Exemptions) without issuing any show cause notice and without 2 affording a reasonable opportunity of being heard before such rejection. It was also contended that such action is violative of the principles of natural justice. 4. Thus, against the order ... deserves to be set aside and the matter may be restored to CIT(E) file for fresh adjudication, after affording due and reasonable opportunity of being heard to the assessee. 6. The Ld. CIT-DR relied on the order of Ld. CIT(E) to state that no charitable activities

Endocrine and Breast Surgery Foundation, Chandigarh vs. Commissioner of Income Tax Exemptions, Chandigarh

In the result, both the above appeals of the Assessee are dismissed

ITA 244/CHANDI/2025[2025-26]Status: DisposedITAT Chandigarh08 Oct 2025AY 2025-26

Bench: Such Rejection. It Was Also Contended That Such Action Is Violative Of The Principles Of Natural Justice.

For Appellant: Shri S.K. Bhasin and Shri K.B. Sood, CA’sFor Respondent: Shri Manav Bansal, CIT, DR
Section 12ASection 12A(1)(ac)Section 2(15)Section 80G(5)

rejected by the Ld. CIT (Exemptions) without issuing any show cause notice and without 2 affording a reasonable opportunity of being heard before such rejection. It was also contended that such action is violative of the principles of natural justice. 4. Thus, against the order ... deserves to be set aside and the matter may be restored to CIT(E) file for fresh adjudication, after affording due and reasonable opportunity of being heard to the assessee. 6. The Ld. CIT-DR relied on the order of Ld. CIT(E) to state that no charitable activities

ACIT, CC-2, Chandigarh vs. Shri Karaj Singh, Yamuna Nagar

In the result, the revenue’s appeal ITA No

ITA 726/CHANDI/2022[2018-19]Status: DisposedITAT Chandigarh08 Oct 2025AY 2018-19

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No. 726/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2018-19) Acit-Central Circle 2 Shri Karaj Singh बनाम/ Cr Building Sector 17 H. No 1379, Modern Colony, Near Iti Vs. Chandigarh 160017 Yamuna Nagar (Haryana) "ायीलेखासं./जीआइआरसं./Pan/Gir No. Atups-5528-A (अपीलाथ"/Appellant) (""थ" / Respondent) : & 2. Co. No. 16/Chandi/2024 [In Ita No. 726/Chandi/2022 (िनधा"रण वष" / Assessment Year: 2018-19) Shri Karaj Singh Acit-Central Circle 2 बनाम/ H. No 1379, Modern Colony, Near Iti, Cr Building Sector 17 Vs. Yamuna Nagar (Haryana) Chandigarh 160017 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Atups-5528-A (Cross-Objector) : (Respondent) Revenue By : Smt. Kusum Bansal (Cit) – Ld. Dr Assessee By : Shri Dhruv Goel (Ca) - Ld. Ar सुनवाईकीतारीख/Date Of Hearing : 18-09-2025 घोषणाकीतारीख /Date Of Pronouncement : 08/10/2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1.1 Aforesaid Appeal By Revenue For Assessment Year (Ay) 2018-19 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)- 3, Gurgaon [Cit(A)] Dated 26-09-2022 In The Matter Of An Assessment

For Appellant: Shri Dhruv Goel (CA) - Ld. ARFor Respondent: Smt. Kusum Bansal (CIT) – Ld. DR
Section 143(3)Section 153Section 153ASection 153DSection 68

deserve to be quashed as such. 6. That the authorities below have erred in making/confirming additions without providing adequate opportunity of being heard to the assessee and without adhering to the principles of natural justice. 7. The assessee craves leave to add, amend, alter, substitute or revise

Nidra Hospitality Gujarat Private Limited, Vadodara vs. The ACIT, Circle Intl. Taxn., Vadodara

In the result, the appeal of the assessee is allowed

ITA 882/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad08 Oct 2025AY 2017-18

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2017-18

For Appellant: Ms. Kinjal Shah, A.RFor Respondent: Shri Kamal Deep Singh, Sr. D.R
Section 143(3)Section 195Section 201Section 201(1)Section 250Section 40a

that the appellate order passed u/s 250 of the Act by the NFAC which is in haste and hurry and without giving reasonable opportunity of being heard to the appellant. The assessment was completed on presumption, guess work and the same be deleted. I.T.A No. 882/Ahd/2025 Nidra Hospitality Gujarat

Dhananjay Tradelink Pvt. Ltd., Ahmedabad vs. The ITO, Ward-1(1)(3), Ahmedabad

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

ITA 842/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad08 Oct 2025AY 2018-19

Bench: Dr. B.R.R. Kumar, Vice-Ms Suchitra Kamble

For Appellant: Shri S.N Divetia, with Shri Samir Vora, ARsFor Respondent: Shri Rignesh Das, CIT. DR
Section 133(6)Section 143(3)Section 250Section 68

restore the matter back to the file of the Assessing Officer for de novo assessment, after affording due opportunity of being heard to the assessee. The assessee shall submit all the relevant bank statement/submission/document before the Assessing Officer and Asst. Year : 2018-19 - 4– comply with the notices issued

Na Roto Machine & Moulds India, Ahmedabad vs. The ACIT, Circle-3(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1349/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad08 Oct 2025AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2017-18

Section 133ASection 147Section 148ASection 270A

than search cases), the Assessing Officer shall conduct enquiries with reference to the information of escapement of income, if required, and provide an opportunity of being heard to the assessee. After considering the reply of the assessee, the Assessing Officer shall decide, by passing an order, whether

Pitti Holdings Private Limited, Hyderabad vs. ACIT., Central Circle-1(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 450/HYD/2025[2018-19]Status: DisposedITAT Hyderabad08 Oct 2025AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.450/Hyd/2025 (िनधा"रण वष"/Assessment Year:2018-19) M/S. Pitti Holdings Pvt. Asst. Commissioner Of Vs. Ltd., Hyderabad. Income Tax, Central Circle Pan: Aagcp3824Q 1(1), Hyderabad. (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Shri A. Srinivas, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 09/09/2025 घोषणा की तारीख/Pronouncement: 08/10/2025

For Appellant: Shri A. Srinivas, C.AFor Respondent: Dr. Sachin Kumar, DR
Section 148Section 148A

148A of Income-tax 1961 and in accordance with the provisions of sec 27 ITA.No.450/Hyd./2025 151, the assessee was provided an opportunity of being heard by issuance of show cause notice u/s 148(A)(b) of the Income-tax Act, 1961 dated 12.03.2022, with prior approval from

Mohd Azgar Ali, Nalgonda vs. ITO., Ward-1, Nalgonda

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

ITA 1283/HYD/2025[2017-18]Status: HeardITAT Hyderabad08 Oct 2025AY 2017-18

Bench: SHRI G. MANJUNATHA, HON’BLE (Accountant Member), SHRI RAVISH SOOD, HON’BLE (Judicial Member)

Section 139(1)Section 142(1)Section 144(1)Section 144BSection 147Section 148Section 148ASection 151ASection 69A

issue to the file of the A.O. with a direction to redo the assessment afresh in accordance with law after providing a reasonable opportunity of being heard to the assessee. 5. Aggrieved by the order of the Ld. CIT(A), the assessee is now in appeal before the Tribunal ... proceedings to the file of the A.O. with a direction to redo the assessment afresh in accordance with law after providing a reasonable opportunity of being heard to the assessee. 9. Insofar as the arguments of the learned counsel for the assessee in light of the decision

Sesham Ramanaiah, Prakasam vs. ITO., Ward-1, Ongole

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

ITA 1062/HYD/2025[2016-17]Status: FixedITAT Hyderabad08 Oct 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Ms. Swathi Sheela, C.AFor Respondent: Dr. Sachin Kumar, SR-DR
Section 139Section 147Section 148Section 69Section 69A

land, proof of cultivation and actual earning of agricultural income. The Ld. AO shall verify and decide the issue afresh after granting due opportunity of being heard. 10. As regards the second issue of addition of Rs.56,45,000/- under section 69, we note that the assessee gave inconsistent explanations ... loan agreements, and any other proof that the assessee may file. The Ld. AO shall adjudicate the matter de novo after affording adequate opportunity of being heard to the assessee. 11. In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced in the open Court

Vitp Private Limited, Hyderabad vs. DCIT., Circle8(1), Hyderabad

ITA 573/HYD/2024[AY 2017-18]Status: DisposedITAT Hyderabad08 Oct 2025

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.573 & 574/Hyd/2024 (निर्धारण वर्ष/Assessment Year: 2017-18) Vitp Private Limited Vs. Dy. Cit Hyderabad Circle 8 (1) Pan:Aaccv2672G Hyderabad (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Advocates Percy Perdiwala & Mahima Goud राजस्व द्वारा / Revenue By:: Shri Shahnawaz-Ul-Rahman, Cit(Dr) सुनवाई की तारीख / Date Of Hearing: 23/09/2025 घोषणा की तारीख / Pronouncement: 08/10/2025 आदेश/Order Per Madhusudan Sawdia, A.M.: These Two Appeals Are Filed By Vitp Private Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Principal Commissioner Of Income Tax-2, Hyderabad, (“Ld.Pcit”), Dated 30/03/2024 For The A.Y.2017-18. As Both The Appeals Are Interrelated & Belongs To The Same, Both Are Heard Together & One Consolidated Order Is Being Passed For The Sake Of Brevity.

For Appellant: Advocates Percy Perdiwala andFor Respondent: : Shri Shahnawaz-ul-Rahman
Section 143(3)Section 144BSection 144C(3)Section 263Section 80Section 801A

ITA Nos 573 and 5754 of 2024 VIP Private Limited आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE

A R Udyog, Howrah vs. ITO, Ward 46(3), Kolkata

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

ITA 1166/KOL/2025[2011-2012]Status: DisposedITAT Kolkata08 Oct 2025AY 2011-2012

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 139Section 144Section 148Section 250Section 68

order of the Ld. CIT(A) is hereby set aside and the issue is remanded to the Ld. AO who shall allow an opportunity of being heard to the assessee and the assessee shall produce all evidences in support of the genuineness of the transactions and AO shall confront