“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

Mayank Jain, Sagar vs. Income Tax Officer, Sagar

In the result, the appeal is partly allowed for statistical purposes

ITA 197/JAB/2024[2017-18]Status: DisposedITAT Jabalpur01 Sept 2025AY 2017-18

Bench: Shri Anadee Nath Misshra

Section 144Section 147Section 69

file of the Assessing Officer with the direction to pass de novo assessment order in accordance with law after providing reasonable opportunity of being heard to the assessee. The learned Departmental Representative expressed no objection to this, and left the matter to the discretion of Bench. In view ... file of the Assessing Officer with the direction to pass de novo assessment order in accordance with law after providing reasonable opportunity of being heard to the assessee. (D) In the result, the appeal is partly allowed for statistical purposes. (Order pronounced in the open court on 01/09/2025) . Dated:01/09/2025

Bala Prasad Patel, Chhatarpur vs. Income Tax Officer, Chhatarpur

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

ITA 139/JAB/2024[2011-12]Status: DisposedITAT Jabalpur01 Sept 2025AY 2011-12

Bench: Shri Anadee Nath Misshra

Section 147Section 253(3)

back to the file of learned CIT(A) with the direction to pass de novo order, in accordance with law, after providing reasonable opportunity of being heard to the assessee. (E) In the result, the appeal of the assessee is partly allowed for statistical purposes. (Order pronounced in the open

Mudrika Prasad Tiwari, Rewa vs. Income Tax Officer Ward-1, Rewa

In the result, the appeal is partly allowed for statistical purposes

ITA 111/JAB/2024[2015-16]Status: DisposedITAT Jabalpur01 Sept 2025AY 2015-16

Bench: Shri Anadee Nath Misshra

Section 144Section 147

Narendra Kumar Khatri, Patna vs. ITO, Ward- 5 (3), Patna

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

ITA 307/PAT/2025[2014-15]Status: DisposedITAT Patna01 Sept 2025AY 2014-15

Bench: S/Shri George Mathan & Rajesh Kumarassessment Year : 2014-15 Narendra Kumar Khatri, Prop. Sri Vs. Income Tax Officer, Ward 5(3), Jewellery House Manisha Patna Complex, Bakerganj, Patna Pan/Gir No. Afxpk 7161 G (Appellant) .. ( Respondent) Assessee By : Shri Sujay Sen, Adv, Adv Revenue By : Shri Ashwani Kumar, Sr. Dr Date Of Hearing : 01/09/2025 Date Of Pronouncement : 01/09/2025 O R D E R

For Appellant: Shri Sujay Sen, Adv, AdvFor Respondent: Shri Ashwani Kumar, Sr. DR

natural justice, and 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, we also hereby caution the assessee to promptly co-operate with the proceedings before

Sanjeev Kumar, Patna vs. ITO, Ward- 6 (1), Patna

The appeal of the assessee is allowed for statistical purposes

ITA 264/PAT/2025[2014-15]Status: DisposedITAT Patna01 Sept 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.264/Pat/2025 Assessment Year: 2014-15 Sanjeev Kumar...……………………………. …………………....Appellant Om Enterprises, Main Bazar, Bihta, Bihar- 801503. [Pan: Aswpk7096A] Vs. Ito, Ward-6(1), Patna……..…..……………..………………….…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Smt. Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 19, 2025 Date Of Pronouncing The Order : September 1St, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 17.01.2025 Passed By The Nfac Under Section 250 Of The Income-Tax Act, 1961. 2. At The Outset, It Is Noted That There Is A Delay Of 56 Days In Filing The Present Appeal Before The Tribunal. The Assessee Has Filed A Condonation Petition Explaining The Reasons Or Such Delay. After Considering The Submissions & Materials On Record, We Are Satisfied That There Was Reasonable Cause For The Delay In Filing The Appeal. Accordingly, The Said Delay Is Condoned & The Appeal Is Admitted For Adjudication.

Section 250

matter back to the file of the ld. CIT(A) with a direction to re-examine the issue afresh after giving reasonable opportunity of being heard to the assessee and to decide the appeal on merits of the case. We direct the assessee to comply all notices during the remand

Rubi Kumari, Samastipur vs. ITO, Ward- 3 (3), Samastipur

The appeal of the assessee is allowed for statistical purposes

ITA 263/PAT/2025[2017-18]Status: DisposedITAT Patna01 Sept 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.263/Pat/2025 Assessment Year: 2017-18 Rubi Kumari….……………………………. …………………....Appellant C/O Maa Tarini Auro Services, Belsanditara, Bibhutipur, Samastipur, Bihar- 848207. [Pan: Akupk7000Q] Vs. Ito, Ward-3(3), Samastipur…..……………..………………….…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Smt. Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 19, 2025 Date Of Pronouncing The Order : September 1St, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 20.03.2025 Passed By The Nfac Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Ate That The Assessee Is An Individual & Derived Her Income From Petrol Pump. For The Assessment Year 2017- 18, The Assessee Filed Her Return Of Income Declaring Total Income Of Rs.9,75,504/-. The Assessing Officer Found During The Assessment Proceedings That There Was Discrepancy In Disclosing Of Closing Stock Amounting To Rs.264871/- & The Assessee Had Unexplained Expenditure Of Rs.10,68,685/- & The Assessee Received Undisclosed Interest From Investments Of Rs.31,006/- & There Was

Section 250

Dineshwar Prasad, Sarvadya Kamla Apartment, Boring Road vs. Deputy Commissioner of Income Tax, Circle-4, Patna, Not Known

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

ITA 250/PAT/2025[2014-15]Status: DisposedITAT Patna01 Sept 2025AY 2014-15

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.250/Pat/2025 Assessment Year: 2014-15 Dineshwar Prasad.………………………. …………………....Appellant Sarvadya Kamla Apartment, An Path, North S K Puri, Boring Road, Patna - 800013. [Pan: Acwpp8473C] Vs. Dcit, Circle-4, Patna…..…..……………..………………….…..... Respondent Appearances By: Shri S.S.P Singh, Fca Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 18, 2025 Date Of Pronouncing The Order : September 1St, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 21.02.2023 Passed By The Nfac, Delhi Under Section 250 Of The Income-Tax Act, 1961. 2. At The Outset, It Is Noted That There Is A Delay Of 749 Days In Filing The Present Appeal Before The Tribunal. The Assessee Has Filed A Condonation Petition Explaining The Reasons Or Such Delay. After Considering The Submissions & Materials On Record, We Are Satisfied That There Was Reasonable Cause For The Delay In Filing The Appeal. Accordingly, The Said Delay Is Condoned & The Appeal Is Admitted For Adjudication.

Section 250Section 69

restore the matter to the file of the ld. CIT(A) with a direction to provide a reasonable opportunity of being heard to the assessee and to adjudicate the appeal afresh after considering the documents and submissions that may be filed in support of his case. The assessee is also

Sanjay Kumar Sharma, Bhagalpur vs. PCIT-1, Patna

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

ITA 209/PAT/2025[2013-14]Status: DisposedITAT Patna01 Sept 2025AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.209/Pat/2025 Assessment Year: 2013-14 Sanjay Kr. Sharma…………………………. …………………....Appellant S/O Chidanand Sharma, Radha Rani Sinha Road, Adampur, Bhagalpur, Bihar- 812001... [Pan: Awips0681B] Vs. Ito, Ward-1(1), Bhagapur..…..……………..………………….…..... Respondent Appearances By: Shri Sudipta Sannigrahi, Ca Appeared On Behalf Of The Appellant. Smt. Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 20, 2025 Date Of Pronouncing The Order : September 01, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 28.02.2025 Passed By The Nfac Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Filed Return Of Income For The Assessment Year 2013–14 Declaring Total Income Of Rs.10,60,000/-. The Case Of The Assessee Was Reopened By Issuing Notice U/S 148 Of The Act After Obtaining Due Approval. Subsequently, The Assessing Officer Completed The Assessment By Passing Order U/S 147 R.W.S. 144B Of The Act By Making An Addition Of Rs.20,87,245/- On Account Of Undisclosed Credits.

Section 147Section 148Section 250

matter to the file of the ld. CIT(A) for fresh adjudication in accordance with law, after affording the assessee a reasonable opportunity of being heard and to submit necessary supporting documents. The assessee is also directed to cooperate in the proceedings without fail. Thus, the appeal of the assessee

Girish Chandra, Patna vs. ITO, Ward- 4(3), Patna

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

ITA 615/PAT/2024[2016-17]Status: DisposedITAT Patna01 Sept 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.615/Pat/2024 Assessment Year: 2016-17 Girish Chandra……………………………. …………………....Appellant S/O Harsukh Rai Vyas, Nai Sarak, 11/A Devaki Complex, Chowk Patna City, Patna-800008. [Pan: Afrpc1879H] Vs. Ito, Ward-4(3), Patna……..……………..………………….…..... Respondent Appearances By: Shri Pradeep Kr., Ca Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 18, 2025 Date Of Pronouncing The Order : September 1St, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 07.12.2023 Passed By The Commissioner Of Income Tax, Appeal Addl/Jcit(A)-1, Delhi Under Section 250 Of The Income-Tax Act, 1961. 2. At The Outset, It Is Noted That There Is A Delay Of 253 Days In Filing The Present Appeal Before The Tribunal. The Assessee Has Filed A Condonation Petition Explaining The Reasons Or Such Delay. After Considering The Submissions & Materials On Record, We Are Satisfied That There Was Reasonable Cause For The Delay In Filing The Appeal. Accordingly, The Said Delay Is Condoned & The Appeal Is Admitted For Adjudication.

Section 250Section 69A

Bipin Kumar, Vaishali vs. ITO Ward 1(3), Vaishali

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

ITA 463/PAT/2024[2017-18]Status: DisposedITAT Patna01 Sept 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.463/Pat/2024 Assessment Year: 2017-18 Bipin Kumar….……………………………. …………………....Appellant Patepur Paura Kartaha Vaishali Bihar 844117, Bihar-844117. [Pan: Bnepk5098Q] Vs. Ito, Ward-1(3), Vaishali.…..……………..………………….…..... Respondent Appearances By: Shri Ravi Shankar, Adv., Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 18, 2025 Date Of Pronouncing The Order : September 1St, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 05.01.2024 Passed By The Nfac Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That Notice U/S 142(1) Of The Act Was Issued For Calling Return Of Income For The Assessment Year 2017-18. However, The Assessee Failed To Furnish His Return Of Income For The Assessment Year In Question Either U/S 139 On Or Before 31.03.2018 & Failed To Furnish Itr In Response To Notice Issued U/S 142(1) Of The Act. Later On, The Assessing Officer Got Information That The Assessee Has Deposited Total Cash Amounting To Rs.83,67,203/- In His Bank Account During The Demonetisation Period. As There Was No Compliance On Behalf Of The Assessee, The Assessing Officer Treated The Entire Cash

Section 115BSection 139Section 142(1)Section 250Section 69A

Abinash Jha, Patna vs. ITO Ward 4(5), Patna

The appeal of the assessee is allowed for statistical purposes

ITA 220/PAT/2023[2016-17]Status: DisposedITAT Patna01 Sept 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.220/Pat/2023 Assessment Year: 2016-17 Abinash Jha…....……………………………. …………………....Appellant Flat No.304, Gauri Shankar Complex, Lohiya Nagar, Kankarbagh, Patna Bihar- 800020. [Pan: Afppj3114G] Vs. Ito, Ward-4(5), Patna……..…..……………..………………….…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Smt. Rinku Singh, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : August 20, 2025 Date Of Pronouncing The Order : September 1St, 2025

Section 250

whole issue to the file of the Assessing Officer with a direction to re-examine the issue afresh after giving reasonable opportunity of being heard to the assessee. We direct the assessee to comply all notices and submit all the necessary documents during the remand proceedings. 8. In terms

Govind Jee, Jaipur vs. ITO Ward -1(1), Jaipur

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

ITA 1040/JPR/2025[2017-18]Status: DisposedITAT Jaipur01 Sept 2025AY 2017-18

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri R.S. Poonia,CAFor Respondent: Shri Gautam Singh Choudhary, JCIT-DR

Section 69A

Hence, the matter is restored to the file of the AO to decide it afresh in accordance with law by providing one more opportunity of being heard to the assessee. However, the assessee will not seek any adjournment on frivolous ground and 6 SHRI GOVIND JEE VS ITO, WARD

Life Eternal Trust, Nashik vs. CIT Exemption, Pune

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

ITA 916/PUN/2025[-]Status: DisposedITAT Pune01 Sept 2025

Bench: Shri R. K. Panda & Ms. Astha Chandralife Eternal Trust Cit(Exemption), Pune 1016, Shukla Lane, Vs. Nashik – 422001 Pan: Aaatl3389H (Appellant) (Respondent) Assessee By : Shri Bhuvanesh Kankani Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 20-08-2025 Date Of Pronouncement : 01-09-2025 O R D E R

For Appellant: Shri Bhuvanesh KankaniFor Respondent: Shri Amol Khairnar, CIT-DR

Section 3Section 80G

expenses claimed. Therefore, the trust has failed to establish the genuineness of its activities. He further noted that the assessee was specifically given opportunity of being heard to offer its explanation with credible evidence. However, the assessee did not avail of the said opportunity nor submitted any credible evidence ... claimed by the assessee despite a specific query. Thus, the trust failed to establish genuineness of activities. Further, the assessee was specifically given opportunity of being heard vide the notice dated 11/09/2024 to offer its explanation with credible evidences to show cause notice points

Girish Kishanlal Sharma, Kolkata vs. Income Tax Officer, Ward - 34(1), Kolkata

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

ITA 1405/KOL/2025[2016-17]Status: HeardITAT Kolkata01 Sept 2025AY 2016-17

Bench: Shri George Mathan & Shri Sanjay Awasthiassessment Year: 2016-17 Girish Kshanlal Sharma Ito, Ward-34(1), Kolkata Vs Room No.218, Old China Bazaar Street, Kol-1. (Pan: Ansps3752Q) (Appellant) (Respondent)

For Appellant: NoneFor Respondent: Shri Sandip Sarkar, Sr. DR- JCIT

before the ld. CIT(A) and the ld. CIT(A) has dismissed the appeal of the assessee ex parte without providing any sufficient opportunity of being heard to the assessee. This being so, in the interest of justice, we grant the assessee one more opportunity to substantiate his claim before ... restoring the issues in the appeal to the file of ld. CIT(A) for adjudicating afresh after providing the assessee adequate opportunity of being heard. The assessee shall produce all the supporting documents to substantiate his claim and shall cooperate in the re-adjudication proceedings positively. 6. In the result

Kalpanik Vyapaar Pvt. Ltd., Kolkata vs. I.T.O., Ward - 4(4), Kolkata

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

ITA 1124/KOL/2025[2009-2010]Status: DisposedITAT Kolkata01 Sept 2025AY 2009-2010

Bench: Shri George Mathan & Shri Sanjay Awasthiassessment Year: 2009-10 Kalpanik Vyapaar Pvt. Ltd. Ito, Ward-4(4), Kolkata Vs 32, Ezra Street, 5Th Floor, Kol-1. (Pan: Aadck3638E) (Appellant) (Respondent)

For Appellant: Shri Miraj D. Shah, ARFor Respondent: Shri P. N. Barnwal, CIT-DR

Section 131Section 263

transactions. The issues in this appeal are restored to the file of the Assessing Officer for readjudication after granting the assessee adequate opportunity of being heard subject to payment of cost of Rs.1,00,000/- 2 Kalpanik Vyapaar Pvt. Ltd. on the assessee to be payable to the Legal

Ashutosh Biswas, Burdwan vs. ITO, Ward 1(1), Burdwan

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

ITA 1070/KOL/2025[2017-2018]Status: DisposedITAT Kolkata01 Sept 2025AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 142(1)Section 147Section 148Section 250Section 250(6)Section 271ASection 69A

accounts which were not disclosed. The Ld. AR requested that the matter may be remanded to the Ld. CIT(A) so that adequate opportunity of being heard can be provided to the assessee. 5. We have considered the submissions made. We are of the view that on the reasons given ... hereby set aside and we remit the matter back to the Ld. CIT(A) who shall allow the opportunity of being heard to the assessee and thereafter pass a speaking order on the grounds of appeal raised before him. I.T.A. No.: 1070/KOL/2025 Assessment Year: 2017-18 Ashutosh Biswas

Kaushik Mondal, Kolkata vs. I.T.O., Ward - 61(2), Kolkata

Appeal is allowed for statistical purposes

ITA 1158/KOL/2024[2012-2013]Status: DisposedITAT Kolkata01 Sept 2025AY 2012-2013

Bench: 2 Kaushik Mondal The Ld. Cit(A) Also The Assessee Could Not Succeed As It Was Held That Evidence Was Not Produced To Substantiate The Impugned Deposits As Being Out Of Gifts Received.

Section 250Section 69A

aside the impugned order and remand this matter back to the file of Ld. AO for fresh assessment, after giving an opportunity of being heard. 4. In result, this appeal is allowed for statistical purposes. Order pronounced on 01.09.2025 (George Mathan) (Sanjay Awasthi) Judicial Member Accountant Member Dated

Rotary Bangalore Orion Gateway Trust, Bengaluru vs. Income Tax Officer (Exemptions) Ward 3, Bengaluru

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

ITA 446/BANG/2025[2025-26]Status: DisposedITAT Bangalore01 Sept 2025AY 2025-26

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: Na

For Appellant: Sri Mahendra, A.RFor Respondent: Sri Murali Mohan, D.R

Section 80GSection 80G(5)

submitted that the ld. CIT(E) hastily & mechanically passed the order cancelling the approval u/s 80G(5) of the Act without providing sufficient opportunity of being heard to the assessee which is a gross violation of the principles of natural justice and accordingly prayed to grant one more opportunity before ... reply/documents in response to hearing notices dated 18/10/2024 & 09/11/2024. We also observe that the ld. CIT(E) failed to provide a final opportunity of being heard before rejecting the application which in our opinion is a gross violation of the principles of natural justice Before

Okkaliga Gowda Seva Sangha Kadaba, Dakshina Kannada vs. Commissioner of Income Tax, (Exemptions), Bengaluru

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

ITA 353/BANG/2025[2024-25]Status: DisposedITAT Bangalore01 Sept 2025AY 2024-25

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Gokul, A.RFor Respondent: Sri Murali Mohan, D.R

Section 12ASection 80G

further activities carried on the said building & its present status along with the other activities of the Trust. Needless to say, a reasonable opportunity of being heard must be granted to the assessee. We also direct the assessee to produce/submit all the necessary details/documents/record/ financials/reports in support of its claim

Okkaliga Gowda Seva Sangha Kadaba, Dakshina Kannada vs. Commissioner of Income Tax (Exemptions), Bengaluru

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

ITA 352/BANG/2025[2024-25]Status: DisposedITAT Bangalore01 Sept 2025AY 2024-25

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Sri Gokul, A.RFor Respondent: Sri Murali Mohan, D.R

Section 12ASection 80G