“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

Deepak Mulchand Gosar, Mumbai vs. Ward 41(2)(1), Mumbai

Accordingly, Ground No.1 is allowed for statistical purpose and all the other grounds raised by the Assessee are dismissed as having been rendered infructuous

ITA 6046/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Feb 2026AY 2017-18

Bench: The Learned Cit(A) On 20/12/2022 & The Application Filed By The Assessee For Admission Of Additional Evidence To Contend That The Cit(A) Had Dismissed The Appeal After Recording Incorrect Facts.

For Appellant: Shri Shashank MehtaFor Respondent: Shri Annavaran Kosuri

Section 143(1)

Order, dated 31/07/2025, passed by the Ld. CIT(A) with the directions to adjudicate the appeal afresh after granting the Assessee a reasonable opportunity of being heard. 5. Accordingly, Ground No.1 is allowed for statistical purpose and all the other grounds raised by the Assessee are dismissed as having been

M/S. Rajeshwar Bullion Trading, Mumbai vs. Asst. CIT, Circle 23(3), Mumbai

In the result, the appeal is dismissed

ITA 5754/MUM/2025[2017-18]Status: DisposedITAT Mumbai20 Feb 2026AY 2017-18

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarm/S. Rajeshwar Bullion Trading Income Tax Officer 2Nd Floor, 61/63, Ward 23(3)(6) Har Narayan Building, Vs. Mumbai Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Assessee) : (Revenue) & Income Tax Officer M/S. Rajeshwar Bullion Trading Ward 23(3)(6) 2Nd Floor, 61/63, Mumbai Vs. Har Narayan Building, Zaveri Bazar, Mumbai-400 002 Pan/Gir No. Aasfr 7707 D (Revenue) : (Assessee) Appellant By : Shri Dhran Gandhi Respondent By : Shri Annavaram Kosuri (Sr. Ar) Date Of Hearing : 16.02.2026 Date Of Pronouncement : 20.02.2026 O R D E R Per Saktijit Dey: The Captioned Appeals, One By The Assessee & The Other By The Revenue Arise Out Of Two Separate Orders Passed By National Faceless Appeal Centre (‘Nfac’ For Short), Delhi, Pertaining To The Very Same Assessment Year (A.Y. For Short) 2017-18. However, While Assessee’S Appeal Arises Out Of Original Assessment Proceeding, The Revenue’S Appeal Arises Out Of Reassessment Proceeding U/S. 147 Of The Act. M/S. Rajeshwar Bullion Trading 2. At The Outset, We Will Deal With Assessee’S Appeal, Being Ita No.5754/Mum/2025. In Ground Nos. 1 & 2, The Assessee Has Challenged The Decision Of Ld. First Appellate Authority In Remanding The Issue Back To The Assessing Officer (A.O. For Short) For De Novo Adjudication. Whereas, In Ground No. 3, The Assessee Has Challenged The Non-Adjudication Of The Ground Relating To The Applicability Of Section 115Bbe Of The Act. Since, The Issues Are Overlapping, We Will Deal With Them Concurrently.

For Appellant: Shri Dhran GandhiFor Respondent: Shri Annavaram Kosuri (Sr. AR)

Section 115BSection 147Section 68

materials on record, ld. First appellate authority, though, agreed that before rejection of books of accounts, the A.O. has not provided any opportunity of being heard, however, instead of deciding the appeal on merits, he restored the issues back to the A.O. with a direction to reexamine the genuineness

Shri Bharat Navinchandra Gala, Mumbai vs. ITO Ward 41(3)(1), Mumbai

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

ITA 506/MUM/2025[2012-13]Status: DisposedITAT Mumbai20 Feb 2026AY 2012-13

Bench: Smt. Beena Pillai ()

Section 154

rights transferred in respect of the property, and the applicability of the relevant accounting guidance. The Ld. AO shall afford adequate opportunity of being heard to the assessee and decide the issues in accordance with law. 17 I.T.A. No. 506/Mum/2025 6.7. The assessee is also directed to furnish all necessary

Mandir Lodi Mata, Shivpuri vs. The ITO- Ashok Nagar, Gwalior

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

ITA 552/AGR/2025[2020-21]Status: DisposedITAT Agra19 Feb 2026AY 2020-21

Bench: : Shri S. Rifaur Rahmanassessment Year: 2020-21 Mandir Lodi Mata Vs. Income Tax Officer, Narwar Karera Ashok Nagar Shivpuri, Madhya Pradesh Pan : Aaetm2888E (Appellant) (Respondent) Assessee By Shri Naveen Gargh, Adv. Department By Shri Anil Kumar, Sr. Dr Date Of Hearing 19.02.2026 Date Of Pronouncement 19.02.2026 Order

Section 147Section 148Section 148ASection 69A

undisclosed money. Since the assessee has not filed proper details before ld. CIT(A), in my view assessee should be given one more opportunity of being heard for sake of overall justice. Therefore, this matter is remitted to the file of ld. CIT(A) to adjudicate afresh after giving proper ... opportunities of being heard to the assessee. At the same time, the assessee has directed to comply with the notices and submit the relevant information without taking unnecessary adjournments. 7. In the result, appeal filed by the assessee is allowed for statistical purposes. Order pronounced in the open court

Yash Kumar Goyal, Gwalior vs. DCIT/ACIT 2(1), Gwalior

In the result, both appeals filed by the assessee are allowed

ITA 519/AGR/2025[2013-14]Status: DisposedITAT Agra19 Feb 2026AY 2013-14

Bench: : Shri S. Rifaur Rahman

Section 143(3)Section 147Section 148Section 153ASection 153CSection 271(1)(c)Section 274Section 50C

NFAC Dt: 17/09/2025 & the penalty order dated 14/06/2019 is bad in law as it was passed without affording adequate opportunity of being heard, and without considering the detailed explanation and documentary evidence filed by the appellant. 10. That the order of the Ld. CIT(A) NFAC Dt: 17/09/2025 & corresponding penalty

Yash Kumar Goyal, Gwalior vs. DCIT/ACIT 2(1), Gwalior

In the result, both appeals filed by the assessee are allowed

ITA 518/AGR/2025[2012-13]Status: DisposedITAT Agra19 Feb 2026AY 2012-13

Bench: : Shri S. Rifaur Rahman

Section 143(3)Section 147Section 148Section 153ASection 153CSection 271(1)(c)Section 274Section 50C

Anil Kumar Gupta, Subhash Ganj Dabra vs. Commissioner of Income Tax (Appeals), Delhi

In the result, appeal filed by the assessee is allowed

ITA 362/AGR/2025[2017-18]Status: DisposedITAT Agra19 Feb 2026AY 2017-18

Bench: : Shri S. Rifaur Rahmanassessment Year: 2017-18 Anil Kumar Gupta Vs. Commissioner Of Income Tax Pursuhottam Das Company, (Appeals) Subhash Ganj, Dabra Dabra, Dabra Gwalior, Madhya Pradesh Pan : Agnpg8041L (Appellant) (Respondent) Assessee By Shri Alok Dhingra, Adv. Department By Shri Anil Kumar, Sr. Dr Date Of Hearing 16.02.2026 Date Of Pronouncement 19.02.2026 Order

Section 147Section 148Section 69A

assessee is a regular feature and ought to have been accepted in the light of the facts of the case. 5. No proper opportunity of being heard was afforded to the applicant. 6. Other Grounds of appeal will be urged at the time of hearing. Applicant craves leave

Krishna Kumar Gupta, Balaghat vs. Income Tax Officer, Balaghat

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

ITA 73/JAB/2025[2018-19]Status: DisposedITAT Jabalpur19 Feb 2026AY 2018-19

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 144Section 147Section 253(3)

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. In view of the foregoing, and in the specific facts and circumstances of the present case, the order of learned ... pass de novo assessment order on these specific issues in accordance with law after providing reasonable I.T.A. No.73/JAB/2025 Assessment Year:2018-19 3 opportunity of being heard to the assessee. All grounds of appeal are treated as disposed of in accordance with the aforesaid order. (E) In the result

Indian Society of Weed Science, Jabalpur vs. Commissioner of Income Tax (Excemption), Bhopal

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

ITA 48/JAB/2025[-]Status: DisposedITAT Jabalpur19 Feb 2026

Bench: Shri Kul Bharat & Shri, Anadee Nath Misshraassessment Year: Na Indian Society Of Weed V. Commissioner Of Income Science Tax (Exemption) Icar-Dwr Campus, Bhopal Maharajpur, Adhartal, Jabalpur-482004. Pan:Aaaai7305R (Appellant) (Respondent) Appellant By: Shri Sapan Usrethe, Advocate Respondent By: Shri Shravan Kumar Meena, Cit(Dr) Date Of Hearing: 12 02 2026 Date Of Pronouncement: 19 02 2026 O R D E R

For Appellant: Shri Sapan Usrethe, AdvocateFor Respondent: Shri Shravan Kumar Meena, CIT(DR)

Section 12A

satisfied, pass an order in writing rejecting such application and also cancelling its registration after affording a reasonable opportunity of being heard;" According to the Section, the assessee is required to submit (iv) necessary documents to prove the genuineness of the activities of the Trust or institution and also ... attention to the evidences filed before the Ld. CIT(E). It is also stated that the Ld. CIT(E) has not provided sufficient opportunity of being heard to the assessee before passing the rejection order. Therefore, he prayed that the order of the Ld. CIT(E) may be set aside

Shree Agrawal Mandal, Chhindwara vs. Commissioner of Income Tax (Exemption), Bhopal

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 41/JAB/2025[2023-2024]Status: DisposedITAT Jabalpur19 Feb 2026AY 2023-2024

Bench: Shri Kul Bharat & Shri, Anadee Nath Misshra

For Appellant: Shri Dhruv Sahu, CAFor Respondent: Shri Shrawan Kumar Meena, CIT-DR

Section 12ASection 80GSection 80G(5)

assessee to the Ld. CIT(E) for considering the same afresh. Needless to say that the Ld. CIT(E) would afford reasonable opportunity of being heard to the assessee to explain its case. The assessee is also directed to extend full cooperation and furnish the necessary details ... application seeking registration u/s 12AB of the Act to the file of Ld. CIT(E) to decide the same afresh after affording adequate opportunity of being heard to the assessee. The assessee is also directed to extend full cooperation and furnish the necessary details as may be called

Shree Agrawal Mandal, Chhindwara vs. Commissioner of Income Tax (Exemption), Bhopal

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 34/JAB/2025[2023 - 2024]Status: DisposedITAT Jabalpur19 Feb 2026

Bench: Shri Kul Bharat & Shri, Anadee Nath Misshra

For Appellant: Shri Dhruv Sahu, CAFor Respondent: Shri Shrawan Kumar Meena, CIT-DR

Section 12ASection 80GSection 80G(5)

Ramjidas Budhraja Charitable Trust (Sgm), Chhindwara vs. Income Tax Officer Exemption, Jabalpur

In the result, the appeal of the assessee is dismissed

ITA 235/JAB/2025[2015-16]Status: DisposedITAT Jabalpur19 Feb 2026AY 2015-16

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 10Section 11Section 11(2)Section 143(1)Section 143(3)Section 147Section 148

limitation-Only constraint is that any party likely to be affected by considering such new and additional ground must be provided with sufficient opportunity of being heard in that regard-Therefore, Tribunal was not justified in refusing to allow the assessee to raise the additional ground which required application

Umakant Rajoriya, Sagar vs. Income Tax Officer Ward-3, Sagar

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

ITA 82/JAB/2024[2016-17]Status: DisposedITAT Jabalpur19 Feb 2026AY 2016-17

Bench: Shri Anadee Nath Misshra

Section 143(3)Section 68

submissions on merits could not be considered either by the Assessing Officer or by the learned CIT(A). Further, he submitted, reasonable opportunity of being heard was not provided to the assessee. Learned D.R. for Revenue as well as learned A. R. for the assessee were in agreement that ... Assessing Officer with the direction to pass de novo assessment order in accordance with law on this specific issue, after providing reasonable opportunity of being heard to the assessee. All the grounds of appeal are treated as disposed of in accordance with the aforesaid order. I.T.A. No.82/JAB/2024 Assessment Year

Anupama Sthapak, Jabalpur vs. Income Tax Officer Ward 1(3), Jabalpur

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

ITA 25/JAB/2024[2016-17]Status: DisposedITAT Jabalpur19 Feb 2026AY 2016-17

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 143(3)Section 54Section 54F

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 Ld. Counsel for the assessee as well the Ld. Departmental Representative for Revenue were in agreement with this, at the time

Ambikesh Kumar Singh, Sidhi vs. Income Tax Officer, Singrauli

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

ITA 70/JAB/2023[2017-18]Status: DisposedITAT Jabalpur19 Feb 2026AY 2017-18

Bench: Shri Kul Bharat & Shri, Anadee Nath Misshraassessment Year: 2017-18 Ambikesh Kumar Singh V. The Ito – Ward Singrauli Marition School, Ke Samne Singrauli-486886. South Karaundiya Sidhi - 486661. Pan:Dzaps6741C (Appellant) (Respondent) Appellant By: Shri Gagan Tiwari, C.A. Respondent By: Shri Narendra Mulai Prasad, Jc-1 Date Of Hearing: 09 02 2026 Date Of Pronouncement: 19 02 2026 O R D E R

For Appellant: Shri Gagan Tiwari, C.AFor Respondent: Shri Narendra Mulai Prasad, JC-1

Section 143(2)Section 144Section 44ASection 69A

learned lower authorities passed are unlawful and illegal. 3. That the learned lower authorities were not justified in not allowing proper and meaningful opportunity of being heard. 4. That the various findings of the learned lower authorities are opposed to the facts hence the same may kindly be quashed ... Assessing Officer who would verify the claim of the assessee by making necessary inquiry and make assessment afresh, after giving adequate opportunity of being heard to the assessee. Grounds of appeal of the assessee are allowed for statistical purposes. 6. In the result, the appeal of the assessee is allowed

Shri Mohammad Imran Khajawal, Srinagar vs. Income Tax Officer Ward-1, Srinagar

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

ITA 306/ASR/2025[2014-15]Status: DisposedITAT Amritsar19 Feb 2026AY 2014-15

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

For Appellant: None (Adjournment application)

Section 144BSection 148Section 250Section 69A

been passed ex-parte, in blatant violation of the principles of natural justice, as the appellant was not afforded a fair and reasonable opportunity of being heard. The notices under Section 250 were allegedly dispatched to the registered email addresses associated with the appellant's return of income

Shri Abdul Hamid Mir, Kupwara vs. Income Tax Officer Ward-1, Srinagar

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

ITA 266/ASR/2025[2017-18]Status: DisposedITAT Amritsar19 Feb 2026AY 2017-18

Bench: Sh. Udayan Dasgupta & Sh. Krinwant Sahay

For Appellant: Sh. Mohd. Iqbal Untoo, C.A

Section 144Section 250Section 250(4)Section 28Section 44ASection 69A

eyes of law, is against the judicial pronouncements already set as a precedent, having been passed without giving the assessee a proper opportunity of being heard and is in violation of principle of natural justice. 3. That In view of the section

Sanjay Mittal, Ambikapur vs. ACIT, Central Circle, Bilaspur

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

ITA 53/RPR/2026[2018-19]Status: DisposedITAT Raipur19 Feb 2026AY 2018-19

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 53/Rpr/2026 (िनधा"रण वष" Assessment Year: 2018-19) Sanjay Mittal, Hind Unitrade Pvt. Vs Assistant Commissioner Of Income Ltd., Old Bus Stand, Near Maya Tax, Central Circle, Bilaspur, Aaykar Lodge, Ambikapur (C.G.) 497001 Bhawan, Bilaspur (C.G.) 495001 Pan: Adtpm5911C (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri R. B. Doshi, Ca राज" की ओर से / Revenue By : Ms. Bharti Singh, Cit-Dr. सुनवाई की तारीख / Date Of Hearing : 19/02/2026 घोषणा की तारीख / Date Of : 19/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2018-19 Filed By The Assessee Is Directed Against Order Dated 25.11.2025 Of The Commissioner Of Income Tax (Appeals), Raipur-3 [Cit(A)] Passed Under Section 250 Of The Income Tax Act, 1961 (‘Act’).

For Appellant: Shri R. B. Doshi, CAFor Respondent: Ms. Bharti Singh, CIT-DR

Section 132Section 153ASection 250

attention to various paras of the assessment order and impugned appellate order, submitted that reasonable 4 Sanjay Mittal vs. ACIT, Central Circle, Bilaspur opportunities of being heard had been provided to the appellant assessee by the Authorities below; Ld. AO and Ld. CIT(A). However, the appellant assessee tactfully ensured ... matter back to the file of the Ld. CIT(A) for deciding the case afresh/denovo, in accordance with the law, after providing adequate opportunity of being heard to the assessee. We order accordingly. The appellant assessee, no doubt, shall cooperate in remitted appellate proceedings. 8. In the result, this appeal

Deputy Commissioner of Income Tax-(1), Raipur vs. Rajesh Kumar Singh, Raipur

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

ITA 455/RPR/2025[2022-23]Status: DisposedITAT Raipur19 Feb 2026AY 2022-23

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 455/Rpr/2025 (िनधा"रण वष" Assessment Year: 2022-23) Deputy Commissioner Of Income Tax, Vs Rajesh Kumar Singh, New Purena, Circle-1(1), Aaykar Bhawan, Ravigram, Ravigram S O, Civil Lines, Raipur, C. G., 492001. Raipur, Chhattisgarh, 492001 Pan: Ajnps2776H (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri Suraj Gupta, Advocate (Virtually) राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 03/02/2026 घोषणा की तारीख / Date Of : 19/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2022-23 Filed By The Revenue Is Directed Against The Order Dated 13.05.2025 Of The Commissioner Of Income Tax (Appeals), [‘Cit(A)’], National Faceless Appeal Centre (‘Nfac’), Delhi Passed Under Section 250 Of The Income Tax Act, 1961 (‘Act’).

For Appellant: Shri Suraj Gupta, AdvocateFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 133(6)Section 250Section 69C

file of the Ld. CIT(A) for deciding the case afresh/denovo, in accordance with the law and above observations, after providing adequate opportunity of being heard to the 16 DCIT, Circle-1(1) vs. Rajesh Kumar Singh assessee. We order accordingly. The assessee, no doubt, shall cooperate in remitted appellate

Amar Singh Rathore Shikshan Samiti, Raipur vs. Income Tax Officer, Ward-3(1), Raipur

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

ITA 24/RPR/2025[2015-16]Status: DisposedITAT Raipur19 Feb 2026AY 2015-16

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 24/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16) Amar Singh Rathore Shikshan Samiti, Vs Income Tax Officer, Ward-3(1), Netaji Chowk, Katora Talab, Aayakar Bhawan, Civil Lines, Raipur 492001 (C.G.) Raipur Chhattisgarh. Pan: Aacta3313N (अपीलाथ"/Appellant) (""थ" / Respondent) : िनधा"रती की ओर से / Assessee By : Shri Sakshi Gopal Aggarwal, Ca राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 17/02/2026 घोषणा की तारीख / Date Of : 19/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2015-16 Filed By The Assessee Is Directed Against The Order Dated 29.02.2024 Of The Commissioner Of Income Tax (Appeals), [‘Cit(A)’], National Faceless Appeal Centre (‘Nfac’), Delhi Passed Under Section 250 Of The Income Tax Act, 1961 (‘Act’).

For Appellant: Shri Sakshi Gopal Aggarwal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 144BSection 147Section 148Section 148ASection 151ASection 250Section 69A

failed to obtain prion approval of specified authority before conduct of enquiry u/s 148A(a). - That the learned AO failed to provide proper opportunity of being heard as envisaged u/s 148A(b). That the learned AO failed to send SCN as stipulated u/s 148A(b) as well as order ... appellant. Looking to the facts and circumstances of the case, where appellant was not aware of the proceedings and could not avail the opportunity of being heard, the appellant seeks to allow proper opportunity of being heard to represent his case and produce all the facts and documents