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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

Chukhu Tajo, Itangar vs. ITO, Ward North Lakhimpur, North Lakhimpur

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

ITA 39/GTY/2025[2016-17]Status: DisposedITAT Guwahati28 Jul 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm

For Appellant: Shri Anil Kumar Agarwala, ARFor Respondent: Shri Kausik Ray, DR
Section 10(26)Section 144Section 148Section 250Section 250(6)

well as on facts in upholding the order of the assessing officer determining total income of? 62,92,399 without affording reasonable opportunity of being heard to the appellant. ITA Nos. 37 to 43/GHY/2025 Chukhu Tajo; A.Y. 2016-17 2. For that the Learned CIT(A) erred in upholding ... action of the Assessing Officer in passing order u/s 144 without affording effective opportunity of being heard to the assessee, violating the provisions of Natural Justice enshrined in law 3. For that the Leamed CIT(A) erred in upholding the jurisdiction of the Assessing Officer which was assumed without mandatory

Chukhu Tajo, Itanagar vs. ITO, Ward North Lakhimpur, North Lakhimpur

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

ITA 38/GTY/2025[2016-17]Status: DisposedITAT Guwahati28 Jul 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm

For Appellant: Shri Anil Kumar Agarwala, ARFor Respondent: Shri Kausik Ray, DR
Section 10(26)Section 144Section 148Section 250Section 250(6)

well as on facts in upholding the order of the assessing officer determining total income of? 62,92,399 without affording reasonable opportunity of being heard to the appellant. ITA Nos. 37 to 43/GHY/2025 Chukhu Tajo; A.Y. 2016-17 2. For that the Learned CIT(A) erred in upholding ... action of the Assessing Officer in passing order u/s 144 without affording effective opportunity of being heard to the assessee, violating the provisions of Natural Justice enshrined in law 3. For that the Leamed CIT(A) erred in upholding the jurisdiction of the Assessing Officer which was assumed without mandatory

Chukhu Tajo, Itanagar vs. ITO, Ward North Lakhimpur, North Lakhimpur

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

ITA 37/GTY/2025[2016-17]Status: DisposedITAT Guwahati28 Jul 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm

For Appellant: Shri Anil Kumar Agarwala, ARFor Respondent: Shri Kausik Ray, DR
Section 10(26)Section 144Section 148Section 250Section 250(6)

well as on facts in upholding the order of the assessing officer determining total income of? 62,92,399 without affording reasonable opportunity of being heard to the appellant. ITA Nos. 37 to 43/GHY/2025 Chukhu Tajo; A.Y. 2016-17 2. For that the Learned CIT(A) erred in upholding ... action of the Assessing Officer in passing order u/s 144 without affording effective opportunity of being heard to the assessee, violating the provisions of Natural Justice enshrined in law 3. For that the Leamed CIT(A) erred in upholding the jurisdiction of the Assessing Officer which was assumed without mandatory

Veerendra Basavaraj Koujalagi, Belagavi vs. PCIT Hubballi, Hubballi

ITA 103/PAN/2024[2018-2019]Status: DisposedITAT Panaji28 Jul 2025AY 2018-2019

Bench: Hon’Ble Shri Pavankumar Gadale & Shri G. D. Padmahshaliita Nos. 103/Pan/2024 Assessment Year : 2018-19 Veerendra Basavaraj Koujalagi C/O. Shri Laxmi Complex, Sadashiv Nagar, Belgavi-590001 Pan : Agrpk3086D . . . . . . . Appellant V/S The Pr. Commissioner Of Income Tax, Hubali. . . . . . . . Respondent Appearances Assessee By : Mr Shivanand Halbhavi [‘Ld. Ar’] Revenue By : Capt. Pradeep Arya [‘Ld. Dr’] Date Of Conclusive Hearing : 24/06/2025 Date Of Pronouncement : 28/07/2025 Order Per G. D. Padmahshali; The Assessee’S Captioned Appeal Impugns Din & Order 1063626985(1) Dt. 29/03/2024 Passed By Pr. Commissioner Of Income Tax, Hubali [‘Ld. Pcit’] U/S 263 Of The Income-Tax Act, 1961 [‘The Act’] Which Sought To Revise Order Of Assessment Dt. 26/04/2021 Passed U/S 143(3) R.W.S. 144B Of The Act By National Faceless E-Asstt. Centre, Delhi [‘Ld. Ao’] Anent To Assessment Year 2018-19 [‘Ay’].

For Appellant: Mr Shivanand Halbhavi [‘Ld. AR’]For Respondent: Capt. Pradeep Arya [‘Ld. DR’]
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 263

records which triggered the revisionary jurisdiction and thus empowered the Ld. PCIT to conclude the proceedings by making necessary inquiry and according an opportunity of being heard to the appellant that the Ld. AO committed grave mistake by gambolling to verify & vouch applicability of provisions of section

Binod Kumar Kedia, Gopalganj vs. ITO, Ward- 2 (4), Siwan

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

ITA 72/PAT/2025[2013-14]Status: DisposedITAT Patna28 Jul 2025AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 72/Pat/2025 Assessment Year: 2013-2014 Binod Kumar Kedia,……………...…….…………Appellant S/O Latejeevan Ram Kedia, Marwari Mohalla, Gopalganj-841428, Bihar [Pan:Afhpk1798P] -Vs.- Income Tax Officer,……………………………....Respondent Ward-2(4), Siwan Appearances By: Shri K.P. Jalan, C.A., Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 22, 2025 Date Of Pronouncing The Order: July 28, 2025 O R D E R

Section 148Section 250Section 50C

matter back to the file of ld. Assessing Officer to examine these issues afresh and pass a speaking order after providing one more opportunity of being heard to the assessee. 9. In the result, the appeal filed by the assessee is allowed for statistical purposes. Order pronounced in the open

Savitri Devi, Bhojpur vs. NFAC, Delhi

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

ITA 571/PAT/2024[2017-18]Status: DisposedITAT Patna28 Jul 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 142(1)Section 144Section 147Section 148Section 250Section 271ASection 68

well as of the Ld. AO and remit the matter to the Ld. AO to frame the assessment afresh, after affording an opportunity of being heard to the assessee and thereafter pass an order in accordance with law. The assessee shall not seek unnecessary adjournment and shall be at liberty

Aroleen Softech and Engineering Private Limited, Indore vs. Income Tax Officer - 1(1), Indore

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

ITA 116/IND/2025[2013-14]Status: DisposedITAT Indore28 Jul 2025AY 2013-14

Bench: B.M. Biyani & Shri Paresh M Joshiaroleen Softech & Income Tax Officer बनाम/ Engineering Private 1(1), Vs. Limited, Indore 270 Shastri Market, Indore (Pan: Aajca4128P) (Appellant) (Revenue) Assessee By Shri Apurva Mehta, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 24.07.2025 Date Of Pronouncement 28.07.2025 आदेश / O R D E R

Section 144Section 147Section 148Section 149Section 246ASection 250Section 253

erred in upholding the additions made by the Ld. AO made vide Ex-Parte Assessment Order dated 14.11.2019, without providing proper and sufficient opportunity of being heard and thus, the Ex-Parte Order of the Ld. CIT(A), NFAC is liable to be set aside. 3. On the facts

Bhagwan Prasadsinghania HUF, Neemuch vs. AO NFAC, Delhi

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

ITA 850/IND/2024[2013-14]Status: DisposedITAT Indore28 Jul 2025AY 2013-14

Bench: B.M. Biyani & Shri Paresh M Joshibhagwan Prasad Nfac, बनाम/ Singhania Huf, Delhi Vs. 8 Shastri Nagar, Neemuch

Section 115BSection 147Section 246ASection 250Section 253

grossly erred, both on facts and in law, in passing the ex-parte orders without giving proper and effective opportunity of being heard to the appellant. 2. That, without prejudice to the above, the learned CIT(A) grossly erred in not adjudicating the appeal on merits of the case

Dhruv Narayan Singh, Bhopal vs. ITO-2(3), Bhopal

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

ITA 751/IND/2024[2011-12]Status: DisposedITAT Indore28 Jul 2025AY 2011-12

Bench: B.M. Biyani & Shri Paresh M Joshidhruv Narayan Singh, Income Tax Officer बनाम/ E-2/192 Arera Colony, 2(3), Vs. Bhopal Bhopal (Pan: Aprps4102H) (Appellant) (Revenue) Assessee By Ms. Shreya Jain, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 24.07.2025 Date Of Pronouncement 28.07.2025 आदेश / O R D E R

Section 153CSection 154Section 234ASection 234BSection 246ASection 250Section 253

Rs.1,87,549/- and Rs.6,21,054/- respectively. A letter to the assessee was sent by the AO on 31.03.2018 for giving opportunity of being heard for rectifying the mistake which was apparent from the record and date of hearing was fixed on 12.04.2018. The assessee has not submitted

Gulzar Mohd, Malerkotla vs. PCIT (Central), Ludhiana

In the result, appeal of the assessee is allowed

ITA 379/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh28 Jul 2025AY 2018-19

Bench: Shri Rajpal Yadav & Shri Manoj Kumar Aggarwal

For Appellant: Shri Ashwani Kumar &For Respondent: Shri Manav Bansal, CIT, DR
Section 115BSection 133ASection 142(1)Section 143(2)Section 143(3)Section 263Section 69B

Officer is erroneous in so far as it is prejudicial to the interest of the revenue, he may, after giving the assessee 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

Lokhit Mandal Shrirampur, Shrirampur vs. Commissioner of Income-Tax, (Exemptions), Pune

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

ITA 558/PUN/2025[not applicable]Status: DisposedITAT Pune28 Jul 2025

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Bhuvnesh KankaniFor Respondent: Shri Vishwas S. Mundhe
Section 12ASection 12A(1)(ac)

directly relevant to the present proceedings. However. the assessee has failed to comply despite giving sufficient opportunities as discussed above including an opportunity of being heard. 6. Thus, the assessee has failed to furnish the details called for under the provisions of section 12AB(1)(b)(i) of the Income ... aside to the file of the Ld. CIT(E) to adjudicate the same afresh on merits after affording one more opportunity of being heard to the assessee. 6. The Ld. DR had no objection the above request of the Ld. AR. 7. We have heard the Ld. Representatives

Gautam Labdhai Medical and Research Charitable Trust, Pune vs. CIT Exemption, Pune

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

ITA 463/PUN/2025[NA]Status: DisposedITAT Pune28 Jul 2025

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Sharad VazeFor Respondent: Shri Vishwas S. Mundhe
Section 12ASection 12A(1)(ac)

matter may be set aside to the file of the Ld. CIT(E) to adjudicate the same afresh on merits after affording an opportunity of being heard to the assessee. 7. The Ld. DR had no objection the above request of the Ld. AR. 8. We have heard ... assessee’s application for registration afresh and decide the same on merits, in accordance with fact and law after allowing one more opportunity of being heard to the assessee and present its case. Needless to say, the assessee shall provide the requisite support in terms of submitting the relevant details/documentary

Rahul Subhash Naik, Pune vs. Assessment Unit, NFAC, Pune

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

ITA 1478/PUN/2025[2018-19]Status: DisposedITAT Pune28 Jul 2025AY 2018-19

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Ashutosh DhootFor Respondent: Shri Akhilesh Srivastva
Section 250Section 271A

file of ld.CIT(A). Needless to mention that ld.CIT(A) in the course of set-aside proceedings shall afford a reasonable opportunity of being heard to the assessee. Assessee is at liberty to adduce all the required submissions/evidences before ld.CIT(A) to substantiate its case. Assessee is directed to update

Shiv Bahuudheshiya Sevabhavi Sanstha, Beed vs. CIT (Exemption), Pune

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

ITA 1202/PUN/2025[2025-26]Status: DisposedITAT Pune28 Jul 2025AY 2025-26

Bench: Shri R. K. Panda & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1202/Pun/2025 Shiv Bahuudheshiya Vs. Cit (Exemption), Pune. Sevabhavi Sanstha, Majalgaon, Beed- 431122. Pan : Aamts6927Q Appellant Respondent Assessee By Shri Umesh Kumar Mali : Revenue By : Shri Amit Bobde Date Of Hearing : 24.07.2025 Date Of Pronouncement : 28.07.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 05.11.2024 Passed By Ld. Cit, Exemption, Pune Rejecting The Application For Registration U/S 12Ab Of The It Act. 2. Facts Of The Case, In Brief, Are, That The Assessee Filed Application For Registration In Form No.10Ab Under Clause (Iii) Of Section 12A(1)(Ac) Of The It Act On 29.06.2024. With A View To Verify The Genuineness Of Activities Of The Assessee & Compliance

For Respondent: Shri Amit Bobde
Section 12ASection 12A(1)(ac)

directly relevant to the present proceedings. However, the assessee has failed to comply despite giving sufficient opportunities as discussed above including an opportunity of being heard. 6. Thus, the assessee has failed to furnish the details called for under the provisions of section 12AB(1)(b)(i) of the Income

Akhil Bharatiyha Maheshwari Educational & Charitable Trust, Pune vs. CIT Exemption, Pune

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

ITA 2790/PUN/2024[- NA -]Status: DisposedITAT Pune28 Jul 2025

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Shri Nikhil MuthaFor Respondent: Shri Amol Khairnar
Section 12ASection 12A(1)(ac)

matter may be set aside to the file of the Ld. CIT(E) to adjudicate the same afresh on merits after affording an opportunity of being heard to the assessee. 6. The Ld. DR had no objection the above request of the Ld. AR. 7. We have heard ... assessee’s application for registration afresh and decide the same on merits, in accordance with fact and law after allowing one final opportunity of being heard to the assessee and present its case. Needless to say, the assessee shall provide the requisite support in terms of submitting the relevant details/documentary

Income Tax Officer, Ward-7(1), Pune vs. Hemant Bagareddy Motadoo, Pune

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

ITA 1897/PUN/2024[2013-14]Status: DisposedITAT Pune28 Jul 2025AY 2013-14

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2013-14

For Appellant: S/Shri B C Malakar & Yuvraj ChavanFor Respondent: Shri Ramnath P Murkunde
Section 143(2)Section 201Section 40Section 40A(3)Section 68

justice, we deem it proper to restore the issue to the file of the Assessing Officer with a direction to provide due opportunity of being heard to the assessee to substantiate with evidence to his satisfaction that the taxes so deducted have been paid within the stipulated time ... file of the Assessing Officer with a direction to decide the issue afresh and in accordance with law after giving due opportunity of being heard to the assesse. The second issue raised by the Revenue in its grounds of appeal is accordingly allowed for statistical purposes. 19. The third issue

Ganapati Technology Services Pvt. Ltd., Kolkata vs. I.T.O., Ward - 6(3), Kolkata

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

ITA 485/KOL/2025[2016-2017]Status: DisposedITAT Kolkata28 Jul 2025AY 2016-2017

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 485/Kol/2025 Assessment Year: 2016-2017 Ganapati Technology Services Pvt. Ltd.,…Appellant 6B, Dr. Rajendra Prasad Sarani, Kolkata-700001 [Pan:Aadcg2354D] -Vs.- Income Tax Officer,……………………………..Respondent Ward-6(3), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Sanjeev Kadel, A.R., Appeared On Behalf Of The Assessee Shri Susanta Saha, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 21, 2025 Date Of Pronouncing The Order: July 28, 2025 O R D E R

Section 133(6)Section 142(1)Section 143(2)Section 143(3)Section 194ASection 271(1)(c)

back to the file of ld. Assessing Officer to examine the documents afresh with a direction to pass a speaking order after providing 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

Tirupati Cold Storage Pvt. Ltd., Kolkata vs. ITO, Ward 7(1), Kolkata

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

ITA 266/KOL/2025[2018-19]Status: DisposedITAT Kolkata28 Jul 2025AY 2018-19

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 266/Kol/2025 Assessment Year: 2018-2019 Tirupati Cold Storage Pvt. Limited,.………Appellant 79, Sambhunath Pandit Street, Bhawanipur, Kolkata-700020 [Pan:Aabct0126C] -Vs.- Income Tax Officer,……………………………..Respondent Ward-7(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Sheo Prakash Bhatter, Director, Appeared On Behalf Of The Assessee Shri L.N. Dash, Addl. Cit (D.R.), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 08, 2025 Date Of Pronouncing The Order: July 28, 2025 O R D E R

Section 142(1)Section 143(2)

regarding the mode of payments and if it is true or not and to pass a detailed speaking order after providing 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

M/S. Kriti Securities Consultants Pvt. Ltd., Kolkata vs. ITO, Ward-30(1), Kolkata

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

ITA 126/KOL/2025[2021-22]Status: DisposedITAT Kolkata28 Jul 2025AY 2021-22

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 126/Kol/2025 Assessment Year: 2021-2022 M/S. Kriti Securities Consultants Pvt. Ltd,…Appellant 15, India Exchange Place, 1St Floor, Kolkata-700001 [Pan:Abjfm7166M] -Vs.- Income Tax Officer,…………………..…………..Respondent Ward-30(1), Kolkata, Aayakar Bhawan, Dakshin, 2, Gariahat Road (South), Kolkata-700031 Appearances By: Shri Sunil Surana, A.R., Appeared On Behalf Of The Assessee Shri Somnath Das Biswas, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 01, 2025 Date Of Pronouncing The Order: July 28, 2025 O R D E R

Section 115BSection 139(1)Section 139(5)Section 143(1)

erred in confirming the order of the Ld. CPC when the assessee was not allowed any proper and reasonable opportunity of being heard by issuing prior intimation 143(1)(a) before making the impugned adjustments u/s 143(1) of the IT Act and therefore the adjustments are liable ... Addl./JCIT(Appeals) is not justified in confirming the order of ld. CPC when the asessee was not allowed any proper and reasonable opportunity of being heard by issuing prior intimation under section 143(1)(a) of the Act before making the impugned adjustments under section

M/S. Amritlaxmi Vincom Pvt. Ltd., Kolkata vs. I.T.O., Ward - 4(3), Kolkata

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

ITA 2553/KOL/2024[2012-2013]Status: DisposedITAT Kolkata28 Jul 2025AY 2012-2013

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 2553/Kol/2024 Assessment Year: 2012-2013 Amrit Laxmi Vincom Pvt. Ltd.,…………….…Appellant 23A, Netaji Subhash Road, Dalhousie, Room No. 10, 1St Floor, Kolkata-700001, West Bengal [Pan:Aaica5974A] -Vs.- Income Tax Officer,…………………..…………..Respondent Ward-4(3), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Sunil Surana, A.R., Appeared On Behalf Of The Assessee Shri L.N. Dash, Addl. Cit(Dr), Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: May 07, 2025 Date Of Pronouncing The Order: July 28, 2025 O R D E R

Section 144Section 147Section 148

order of ld. Assessing Officer and remit back the issue to the file of ld. Assessing Officer for fresh assessment after providing reasonable opportunity of being heard to the assessee. The ld. CIT(Appeals) opined that ld. Assessing Officer did not adjudicate the grounds of appeal on merits filed