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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

Jhl Trading Limited Liability Partnership, Kochi vs. DCIT, Corporate Cir 1(1), Kochi

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

ITA 17/COCH/2025[2018-2019]Status: DisposedITAT Cochin26 May 2025AY 2018-2019

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadav

For Appellant: Sri.Job Abraham & Sri.Ajay V.Anand, AdvocatesFor Respondent: Sri.Sundarasan S, CIT-DR
Section 139(1)Section 147Section 148

justice, we restore this matter to the file of the AO for examining afresh. Needless to say, the AO shall afford meaningful opportunity of being heard to the assessee. 7. In the result, the appeal filed by the assessee is allowed for statistical purposes. Order pronounced on this 26th

Kerala Muslim Jama-Ath Council, Thiruvananthapuram vs. CIT(Exemptions), Kochi

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

ITA 1068/COCH/2024[2024-25]Status: DisposedITAT Cochin26 May 2025AY 2024-25

Bench: Shri Inturi Rama Rao & Shri Prakash Chand Yadavkerala Muslim Jama-Ath The Commissioner Of Council, Tc 16/458-11, V. Income-Tax (Exemption) Sceond Floor, India Tower Kochi. Edapazhanji, Thycaud So Trivandrum – 695 014. Pan : Aajak3205D. (Appellant) (Respondent) Appellant By : Smt.Divya Ravindran, Advocate Respondent By : Sri.Sundarasan S, Cit-Dr Date Of Pronouncement : 26.05.2025 Date Of Hearing : 22.05.2025. O R D E R Per Prakash Chand Yadav, Jm : The Present Appeal Of The Assessee Is Arising From The Order Of The Learned Commissioner Of Income-Tax (Exemption) [“Cit(E)” For Short] Dated 25.09.2024, Having Din & Order No.Itba/Exm/F/Exm45/2024-25/1069099633(1).

For Appellant: Smt.Divya Ravindran, AdvocateFor Respondent: Sri.Sundarasan S, CIT-DR
Section 12ASection 13(1)(a)

decide the case in accordance with law, after 3 ITA No.1068/Coch/2024. Kerala Muslim Jama Ath Council. according a reasonable opportunity of being heard to the assessee, before passing any order. 5. In the result, the appeal filed by the assessee is allowed for statistical purposes. Order pronounced on this 26th

M/S Baba Kanwar Ram Fruit Co., Alwar vs. ITO, Ward-1(2), Alwar

ITA 375/JPR/2025[2020-21]Status: DisposedITAT Jaipur26 May 2025AY 2020-21

Bench: Nfac, Feeling Aggrieved By The Assessment Order Dated 05.09.2022, Passed By The Assessing Officer. Vide Impugned Order, Learned Cit(A) Dismissed The Appeal Filed By The Assessee & Consequently Upheld The Addition Made. 2. As Regards The Addition, Vide Impugned Order Dated 05.09.2022, The Assessing Officer Assessed Total Income Of The Assessee By Making Addition As Depicted In The Table Below:- Sl. Description Amount (In Inr) No. 1. Income As Per Return Of Income Filed 19,46,350/- 2. Income As Computed U/S 143(1)(A) 19,46,350/- 3. Add: Disallowance Of The Discount 49,16,194/- Paid 4. Total Income/Loss Determined As Per 68,62,544/- The Above Proposal

For Appellant: Sh. P.C. Parwal, C.AFor Respondent: Sh. Gorav Avasthi, JCIT
Section 142(1)Section 143(1)(a)Section 143(2)Section 194NSection 250

granting/availing of discounts, after summoning the relevant parties for the purpose of verification of the said fact, if so desired, provide a reasonable opportunity of being heard to the assessee and then decide the matter afresh as regards grant of discount/ discount expenditure by the assessee on the amount ... restored to the files of Assessing Officer with direction to decide said issue afresh and pass assessment order afresh, after affording reasonable opportunity of being heard to the applicant, in accordance with law. File be consigned to the record room after the needful is done by the office. Order pronounced

Akhil Bharatvarshiya Papeek Ashram Trust, Ajmer vs. CIT Exemption, Jaipur

In the result, the appeals of the assessee in ITA No

ITA 1185/JPR/2024[2024-25]Status: DisposedITAT Jaipur26 May 2025AY 2024-25

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

For Appellant: Sh. Nikhilesh Kataria, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 12ASection 80G

circumstances of the case the assessee may please be directed Without prejudice to above GOA 3: The ld. CIT(Exemption) not provided proper opportunity of being heard Brief facts: In this case, the ld. CIT has passed the order after observing that no reply to the show cause notice ... facts and circumstances, the matter is restored to the file of ld. CIT(E) for afresh adjudication by providing by adequate opportunity of being heard to the assessee regarding the registration of the trust u/s 12AB of the Act. Thus, the appeal of the assessee i.e ITA No. 1184/JP/2024

Akhil Bharatvarshiya Papeek Ashram Trust, Ajmer vs. CIT Exemption, Jaipur

In the result, the appeals of the assessee in ITA No

ITA 1184/JPR/2024[2024-25]Status: DisposedITAT Jaipur26 May 2025AY 2024-25
For Appellant: Sh. Nikhilesh Kataria, CAFor Respondent: Mrs. Alka Gautam, CIT-DR
Section 12ASection 80G

circumstances of the case the assessee may please be directed Without prejudice to above GOA 3: The Id. CIT(Exemption) not provided proper opportunity of being heard Brief facts: In this case, the Id. CIT has passed the order after observing that no reply to the show cause notice ... facts and circumstances, the matter is restored to the file of Id. CIT(E) for afresh adjudication by providing by adequate opportunity of being heard to the assessee regarding the registration of the trust u/s 12AB of the Act. Thus, the appeal of the assessee i.e ITA No. 1184/JP/2024

Aatman Foundation, Gandhinagar vs. The CIT(Exemption), Ahmedabad

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

ITA 364/AHD/2025[NA]Status: DisposedITAT Ahmedabad26 May 2025

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri M K Patel, AdvocateFor Respondent: Shri Ashesh R Rewar, CIT DR
Section 10Section 12ASection 14ASection 80GSection 80G(5)Section 80G(5)(ii)Section 80G(5)(iv)

wrong section code inadvertently while filing the application for final registration in Form 10AB. Further, we notice that assessee did not have the opportunity of being heard before ld. CIT(E) due to incorrect course of action advised, which otherwise assessee might have explained Aatman Foundation vs. CIT(E) Asst.Year

V-One Society, Vadodara vs. The CIT(Exemption), Ahmedabad

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

ITA 287/AHD/2025[NA]Status: DisposedITAT Ahmedabad26 May 2025

Bench: Dr. Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Adjournment Application FiledFor Respondent: Shri Ashesh R Rewar, CIT DR
Section 14ASection 80G

Asst.Year –N.A. - 5– inadvertently while filing the application for final registration in Form 10AB. Further, we notice that assessee did not have the opportunity of being heard before ld. CIT(E) due to incorrect course of action advised, which otherwise assessee might have explained the facts to avoid the impugned

Laxmi Babu Debnath, Pune vs. ITO Ward 7(1), Pune

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

ITA 536/PUN/2025[2013-14]Status: DisposedITAT Pune26 May 2025AY 2013-14

Bench: Ms. Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.535 & 536/Pun/2025 िनधा"रण वष" / Assessment Years: 2012-13 & 2013-14 Laxmi Babu Debnath, V The Income Tax Officer, Level 3, Riverside Business S Ward-7(1), Pune. Bay, Wellesley Road, Near Rto, Pune – 411001. Maharashtra. Pan: Acypd2630F Appellant/ Assessee Respondent / Revenue Assessee By Shri Rajiv Thakkar – Ar Revenue By Shri Madhan Thirmanpallil – Addl.Cit(Dr) Date Of Hearing 14/05/2025 Date Of Pronouncement 26/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeal Filed By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2012-13 & 2013-14 Respectively. These Two Appeals Were Heard Together & Are Being Disposed Of By This Common Order. We Treat Appeal In

Section 143(2)Section 144Section 148Section 249(4)Section 250Section 57

raised by the assessee on merits. Hence, the appeal is set-aside to ld.CIT(A) for denovo adjudication. The Assessee shall be provided opportunity of being heard. Assessee shall file necessary documents before the ld.CIT(A). Accordingly, Ground No.1 of the Assessee is allowed for statistical purpose. 2.5 Since

Laxmi Babu Debnath, Pune vs. ITO Ward 7(1), Pune

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

ITA 535/PUN/2025[2012-13]Status: DisposedITAT Pune26 May 2025AY 2012-13

Bench: Ms. Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita Nos.535 & 536/Pun/2025 िनधा"रण वष" / Assessment Years: 2012-13 & 2013-14 Laxmi Babu Debnath, V The Income Tax Officer, Level 3, Riverside Business S Ward-7(1), Pune. Bay, Wellesley Road, Near Rto, Pune – 411001. Maharashtra. Pan: Acypd2630F Appellant/ Assessee Respondent / Revenue Assessee By Shri Rajiv Thakkar – Ar Revenue By Shri Madhan Thirmanpallil – Addl.Cit(Dr) Date Of Hearing 14/05/2025 Date Of Pronouncement 26/05/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeal Filed By The Assessee Are Directed Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2012-13 & 2013-14 Respectively. These Two Appeals Were Heard Together & Are Being Disposed Of By This Common Order. We Treat Appeal In

Section 143(2)Section 144Section 148Section 249(4)Section 250Section 57

raised by the assessee on merits. Hence, the appeal is set-aside to ld.CIT(A) for denovo adjudication. The Assessee shall be provided opportunity of being heard. Assessee shall file necessary documents before the ld.CIT(A). Accordingly, Ground No.1 of the Assessee is allowed for statistical purpose. 2.5 Since

Anita Mukund Pujari, Solapur vs. ITO, Ward 2(1), Solapur

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

ITA 234/PUN/2025[2015-16]Status: DisposedITAT Pune26 May 2025AY 2015-16

Bench: Shri Rama Kanta Panda, Vice- & Ms. Astha Chandra

For Appellant: Shri P.D. KudvaFor Respondent: Shri Ramnath P. Murkunde
Section 144Section 250Section 69A

that matter may be restored to the file of the Ld. CIT(A)/ AO to decide the case on merits after providing the opportunity of being heard to the assessee. The Ld. DR, on the other hand, supported the order of the Ld. CIT(A)/ AO. 3. We have heard

Alpa India Private Limited, Hyderabad vs. DCIT Circle -1(1), Hyderabad

In the result, the appeal of the assessee company is partly allowed for statistical purposes in terms of our aforesaid observations

ITA 457/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 May 2025AY 2018-19

Bench: Us:

For Appellant: Sri PVSS Prasad, CAFor Respondent: Sri B. Bala Krishna, CIT-DR
Section 115JSection 143(2)Section 143(3)Section 3Section 80Section 80I

receipt u/s 80IC of the Act. Needless to say, the AO shall in the course of the set-aside proceedings afford a reasonable opportunity of being heard to the assessee company which shall remain at liberty to substantiate its claim based on fresh documentary evidence/material, if any. 27 Alpla India

Shriram Translogistics Private Limited, Kolkata vs. DCIT, Circle 13(1), Kolkata

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

ITA 92/KOL/2025[2014-2015]Status: DisposedITAT Kolkata26 May 2025AY 2014-2015

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 92/Kol/2025 Assessment Year: 2014-2015 Shriram Translogistics Pvt. Limited,...………Appellant 150/10, Tagore, Kolkata, Kalagachia, Kolkata-700020 [Pan:Aancs2984F] -Vs.- Deputy Commissioner Of Income Tax,……...Respondent Circle-13(1), Kolkata, Aayakar Bhawan, Income Tax Department, Kolkata-700020 Appearances By: None, Appeared On Behalf Of The Assessee Shri Somnath Das Biswas, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: April 29, 2025 Date Of Pronouncing The Order: May 26, 2025 O R D E R

Section 142(1)Section 147Section 148

natural justice, and remit back to the file of ld. CIT(Appeals) for deciding it afresh with a direction to provide one more opportunity of being heard to the assessee as the ld. CIT(Appeals) dismissed the appeal of the assessee wrongly for want of prosecution due to non-receipt

Sanjay Bagaria, Kolkata vs. I.T.O., Ward - 49(1), Kolkata

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

ITA 2622/KOL/2024[2020-2021]Status: DisposedITAT Kolkata26 May 2025AY 2020-2021

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 2622/Kol/2024 Assessment Year: 2020-2021 Sanjay Bagaria,………………………………………Appellant Block-A, 200, Bangur Avenue, Near Bigpark, Kolkata-700055 [Pan:Advpb4070D] -Vs.- Income Tax Officer,……………………………....Respondent Ward-49(1), Kolkata, Uttarapan Complex, Ultadanga, Maniktala, Civic Centre, Kolkata-700054 Appearances By: Shri Anil Kochar, A.R., Appeared On Behalf Of The Assessee Shri S.B. Chakraborthy, Jcit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: April 9, 2025 Date Of Pronouncing The Order: May 26, 2025 O R D E R

Section 143(1)Section 154

Bench that the ld. CIT(Appeals) passed the ex-parte order without going into merit of the case and without giving sufficient opportunity of being heard. Therefore, ld. Counsel pleaded to set aside the order passed by the ld. CIT(Appeals) and remit the matter back to the file ... that the ld. CIT(Appeals) proceeded to dismiss the appeal of the assessee vide his impugned order passed ex-parte without giving sufficient opportunity of being heard to the assessee. Keeping in view this factual position pointed out by the ld. D.R. from the impugned order

Bma Wealth Creators Academy Private Limited, Kolkata vs. I.to., Ward-12(4), Kolkata

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

ITA 2580/KOL/2024[2012-13]Status: DisposedITAT Kolkata26 May 2025AY 2012-13

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 2580/Kol/2024 Assessment Year: 2012-2013 Bma Wealth Creators Academy Pvt. Ltd.,……Appellant 14/1, Paul Mansion, 6, Bishop Lefroy Road, Kolkata-700020 [Pan:Aaecb2890G] -Vs.- Income Tax Officer,……………………………....Respondent Ward-12(4), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri Miraz D. Shah, A.R., Appeared On Behalf Of The Assessee Shri Akhil Saxena, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: April 8, 2025 Date Of Pronouncing The Order: May 26, 2025 O R D E R

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 249(3)Section 250

before the Bench that the ld. CIT(Appeals) passed the ex-parte order without going into merit of the case and giving sufficient opportunity of being heard. Therefore, ld. Counsel pleaded to set aside the order passed by the ld. CIT(Appeals) and remit the matter back to the file ... Appeals) proceeded to dismiss the appeal of the assessee vide his impugned order passed ex-parte without giving any further opportunity of being heard to the assessee. Keeping in view this factual position pointed out by the ld. D.R. from the impugned order of the ld. CIT(Appeals

Sri Kamaraj Educational Trust, Pudukkottai vs. CIT Exemptions, Chennai

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

ITA 159/CHNY/2025[-]Status: DisposedITAT Chennai26 May 2025

Bench: Shri George George K & Shri Jagadishआयकर अपील सं./Ita No.159/Chny/2025

For Appellant: Shri S. Sridhar, AdvocateFor Respondent: Shri V. Justin, CIT
Section 12ASection 80GSection 80G(5)Section 80G(5)(iv)

consideration. The Ld. CIT(E) is directed to re-examine the application of the assessee u/s. 80G of the Act after affording due opportunity of being heard and taking into account the assessee’s submissions, financial statements, activities in furtherance of its objects, and relevant judicial precedents

R M Prime Solutions, Chennai vs. Assistant Commissioner of Income Tax, Chennai

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

ITA 3362/CHNY/2024[2010-11]Status: DisposedITAT Chennai26 May 2025AY 2010-11

Bench: Shri Ss Viswanethra Ravi & Shri Jagadishआयकर अपील सं./Ita No.3362/Chny/2024 िनधा9रण वष9 /Assessment Year: 2010-11

For Appellant: Shri Bimlendu Bhushan, C.A HIFor Respondent: Shri S. Maruthu Pandian, CIT
Section 143(3)

aside the order passed by the Ld. CIT(A) and remit the matter back to his file for adjudication afresh after affording due opportunity of being heard to the assessee in accordance with law. The assessee is also directed to cooperate with the proceedings and appear before the Ld. Addl

Iljin Automotive Private Limited, Kanchipuram vs. Assistant Commissioner of Income-Tax, Corporate Circle 1(1), Chennai

In the result, appeals filed by the assessee are allowed

ITA 1496/CHNY/2024[2018-19]Status: DisposedITAT Chennai26 May 2025AY 2018-19

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

Section 143(3)Section 154Section 154(3)

Income-tax Act, 1961 ('the Act') dated 19 February 2021 is without jurisdiction as the said order was passed without providing an opportunity of being heard as required under section 154(3) of the Act which is in violation of principles of natural justice and thereby, liable to be quashed ... deductor] [or the collector] of its intention so to do and has allowed the assessee [or the deductor] [or the collector] a reasonable opportunity of being heard. (4) …………… (5) …………. (6) …………. (7) Save as otherwise provided in section 155 or sub-section (4) of section 186, no amendment under this section

Iljin Automotive Private Limited, Irungattukottai vs. Assistant Commissioner of Income-Tax, Corporate Circle 1(1), Chennai

In the result, appeals filed by the assessee are allowed

ITA 1495/CHNY/2024[2017-18]Status: DisposedITAT Chennai26 May 2025AY 2017-18

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

Section 143(3)Section 154Section 154(3)

Income-tax Act, 1961 ('the Act') dated 19 February 2021 is without jurisdiction as the said order was passed without providing an opportunity of being heard as required under section 154(3) of the Act which is in violation of principles of natural justice and thereby, liable to be quashed ... deductor] [or the collector] of its intention so to do and has allowed the assessee [or the deductor] [or the collector] a reasonable opportunity of being heard. (4) …………… (5) …………. (6) …………. (7) Save as otherwise provided in section 155 or sub-section (4) of section 186, no amendment under this section

Iljin Automotive Private Limited, Kanchipuram vs. Assistant Commissioner of Income-Tax, Corporate Circle 2(1), Chennai

In the result, appeals filed by the assessee are allowed

ITA 1494/CHNY/2024[2016-17]Status: DisposedITAT Chennai26 May 2025AY 2016-17

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

Section 143(3)Section 154Section 154(3)

Income-tax Act, 1961 ('the Act') dated 19 February 2021 is without jurisdiction as the said order was passed without providing an opportunity of being heard as required under section 154(3) of the Act which is in violation of principles of natural justice and thereby, liable to be quashed ... deductor] [or the collector] of its intention so to do and has allowed the assessee [or the deductor] [or the collector] a reasonable opportunity of being heard. (4) …………… (5) …………. (6) …………. (7) Save as otherwise provided in section 155 or sub-section (4) of section 186, no amendment under this section

Manjunath Lankappa, Bangalore vs. Income Tax Officer, Ward-7(1)(1), Bangalaore

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

ITA 2160/BANG/2024[2017-18]Status: DisposedITAT Bangalore26 May 2025AY 2017-18

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

For Appellant: Mrs. Adam Kajabee, CAFor Respondent: Shri Subramanian S, CIT (DR)
Section 145Section 147Section 69A

assessee is that the ld. CIT(A) erred in confirming the additions made by the AO without granting a fair and reasonable opportunity of being heard and without considering the nature and documents submitted by the assessee. Page 2 of 5 3. The assessee is an individual and engaged