“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

Dhatri, Secunderabad vs. CIT (Exemption), Hyderabad

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

ITA 1393/HYD/2024[2022-23]Status: DisposedITAT Hyderabad06 May 2025AY 2022-23

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: Smt. S. Sandhya, AdvocateFor Respondent: MS. M. Narmada, CIT-DR

Section 80G

information, the present application in Form-10AB for registration u/sec.80G is infructuous and herewith rejected as non- maintainable. She, accordingly, submitted that, adequate opportunity of being heard to the appellant-trust has not been provided by the learned CIT(E) and, therefore, one more opportunity may please be provided ... this issue back to the file of learned CIT(E) with a direction to re- decide the issue afresh, after providing an adequate opportunity of being heard to the assessee. Accordingly, the grounds of appeal of the assessee are allowed for statistical purposes. 6 ITA.No.1393/Hyd./2024

Marreddy Mekala, Warangal vs. ITO., Ward-1, Warangal

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

ITA 1078/HYD/2024[2015-16]Status: DisposedITAT Hyderabad06 May 2025AY 2015-16

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1078/Hyd/2024 (निर्धारण वर्ा/Assessment Year:2015-16)

For Appellant: Smt. S. Sandhya, AdvocateFor Respondent: : Dr. Sachin Kumar, SR-DR

Section 139(1)Section 147Section 148

file with the direction to adjudicate the grounds raised by the assessee afresh, by passing a speaking and reasoned order after affording due opportunity of being heard to the assessee. 12. In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced in the open Court

Hanumant Niketan Pvt. Ltd., Kolkata vs. ITO, Ward-5(1), Kolkata

In the result, both appeals of the assessee are partly allowed for statistical purposes subject to above directions

ITA 2684/KOL/2024[2013-14]Status: DisposedITAT Kolkata06 May 2025AY 2013-14

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI SANJAY AWASTHI (Accountant Member)

For Appellant: Shri Miraj D. Shah, ARFor Respondent: Shri Nicholas Murmu, Sr. DR

restore the issues in both the appeals to the file of Id. AO for readjudicating the issues afresh after granting the assessee adequate opportunity of being heard. However, looking to the non-cooperation of the assessee during the course of appellate proceedings even after issuance of notices to the assessee

Hanumant Niketan Pvt. Ltd., Kolkata vs. ITO, Ward-5(1), Kolkata

In the result, both appeals of the assessee are partly allowed for statistical purposes subject to above directions

ITA 2683/KOL/2024[2012-13]Status: DisposedITAT Kolkata06 May 2025AY 2012-13

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI SANJAY AWASTHI (Accountant Member)

For Appellant: Shri Miraj D. Shah, ARFor Respondent: Shri Nicholas Murmu, Sr. DR

Priyanka Vinimay Private Limited, Kolkata vs. NFAC, Delhi/ACIT, Ward - 6(1), Kolkata

In the result, both appeals of the assessee are partly allowed for statistical purposes subject to above directions

ITA 2665/KOL/2024[2013-14]Status: DisposedITAT Kolkata06 May 2025AY 2013-14

Bench: us Ld. AR requested that one more opportunity may be granted to the assessee so that the assessee would be able to produce all the required documents before the Ld. CIT(A) to substantiate its case. Thus, in the interest of justice, we restore the issues in both the appeals to the file of Ld. CIT(A) for readjudicating the issues afresh after granting the assessee adequate opportunity of being heard. However, looking to the non-cooperation of the assessee during the course of appellate procee

For Appellant: Shri Amit Agarwal, ARFor Respondent: Shri Nicholas Murmu, Sr. DR

Section 271(1)(c)

issues in both the appeals to the file of Id. CIT(A) for readjudicating the issues afresh after granting the assessee adequate opportunity of being heard. However, looking to the non- cooperation of the assessee during the course of appellate proceedings even after issuance of notices to the assessee

Priyanka Vinimay Private Limited, Kolkata vs. NFAC, Delhi/ACIT, Ward - 6(1), Kolkata

In the result, both appeals of the assessee are partly allowed for statistical purposes subject to above directions

ITA 2664/KOL/2024[2013-14]Status: DisposedITAT Kolkata06 May 2025AY 2013-14

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI SANJAY AWASTHI (Accountant Member)

For Appellant: Shri Amit Agarwal, ARFor Respondent: Shri Nicholas Murmu, Sr. DR

Section 271(1)(c)

Shree Ganesh Stock Advisory Pvt. Ltd., Kolkata vs. DCIT, Central Cir.-3(3), Kolkata

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

ITA 2632/KOL/2024[2014-15]Status: DisposedITAT Kolkata06 May 2025AY 2014-15

Bench: Shri George Mathan & Shri Sanjay Awasthiआयकर अपील सं/Ita No.2632/Kol/2024 (निर्धारण वर्ा / Assessment Year :2014-2015) Shree Ganesh Stock Advisory Vs Dcit, Circle-3(3), Kolkata Private Limited, 7/1A, Room No.401, 4Th Floor, Grant Late, Kolkata Pan No. :Aalcs 6646 J (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररती की ओर से /Assessee By : Shri Miraj D Shah, Ar रधजस्व की ओर से /Revenue By : Shri Nicholas Murmu, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 05/05/2025 घोषणा की तारीख/Date Of Pronouncement : 05/05/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Dated 12.10.2023, Passed By The Cit(A), National Faceless Appeal Centre (Nfac), Delhi In Din & Order No.Itba/Apl/S/250/2023- 24/1057002982(1), For The Assessment Year 2014-2015. 2. Shri Miraj D. Shah Ar Appeared On Behalf Of The Assessee. Shri Nicholas Murmu, Sr. Dr Appeared On Behalf Of The Revenue. 3. It Was The Submission Of The Ld. Ar That The Impugned Order Passed By The Ld. Cit(A) Is An Ex-Parte Order Without Giving Sufficient Opportunity Of Being Heard To The Assessee. It Was Also Submitted That The Assessee May Be Given One More Opportunity To Represent Its Case Before The Ld. Cit(A), So That The Assessee Could Be Able To Provide The Details To Substantiate Its Case For The Year Under Consideration Before The Ld. Cit(A).

For Appellant: Shri Miraj D Shah, ARFor Respondent: Shri Nicholas Murmu, Sr. DR

submission of the ld. AR that the impugned order passed by the ld. CIT(A) is an ex-parte order without giving sufficient opportunity of being heard to the assessee. It was also submitted that the assessee may be given one more opportunity to represent its case before ... justice, we restore the issues to the file of Id. CIT(A) for readjudicating the issues afresh after granting the assessee adequate opportunity of being heard. The assessee is also directed to cooperate with the ld. CIT(A) in the readjudication proceedings, positively. 6. In the result, appeal

Vijay Kalani, Kolkata vs. I.T.O., Ward - 1(1), Asansol

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

ITA 2225/KOL/2024[2017-2018]Status: DisposedITAT Kolkata06 May 2025AY 2017-2018

Bench: Shri George Mathan & Shri Sanjay Awasthiआयकर अपील सं/Ita No.2225/Kol/2024 (निर्धारण वर्ा / Assessment Year : 2017-2018) Vijay Kalani, Vs Ito Ward-1(1), Asansol Satyam Mobile Point, Shabana Market, Asansol Burdwan-713303 Pan No. :Aompk 7766 B (अपीलधर्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्धाररती की ओर से /Assessee By : Shri Vijay Kalani, Assessee In Person रधजस्व की ओर से /Revenue By : Shri Nicholas Murmu, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 06/05/2025 घोषणा की तारीख/Date Of Pronouncement : 06/05/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Dated 30.05.2024, Passed By The Cit(A), National Faceless Appeal Centre (Nfac), Delhi In Din & Order No.Itba/Nfac/S/250/2024- 25/1065240524(1) For The Assessment Year 2017-2018. 2. Shri Vijay Kalani, The Assessee Is Present In Person. Shri Nicholas Murmu, Ld. Sr. Dr Appeared On Behalf Of The Revenue. 3. The Appeal Of The Assessee Is Delayed By 1738 Days Delay. In This Regard, The Assessee Has Filed An Application Along With Affidavit Starting Therein That His Father Was Suffering From Heart Blockage For Which The Assessee Was Busy For Treatment Of His Father. The Assessee Has Enclosed Medical Documents In Respect Of Treatment Of His Father. Thus, The Reasons Stated By The Assessee Are Found To Be Genuine To Which Ld. Sr. Dr Did Not Object To It. Therefore, The Delay Of 1738 Days As Pointed Out By The Registry

For Appellant: Shri Vijay Kalani, assessee in personFor Respondent: Shri Nicholas Murmu, Sr. DR

interest of justice, the issues in this appeal are restored to the file of Assessing Officer for readjudication after granting the assessee adequate opportunity of being heard. 7. In the result, appeal of the assessee is partly allowed for statistical purposes. Order dictated and pronounced in the open court

Nandan Live Stock Development Co-Operative Society Ltd., Burdwan vs. A.C.I.T., Circle - 1, Durgapur

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

ITA 2057/KOL/2024[2017-2018]Status: DisposedITAT Kolkata06 May 2025AY 2017-2018

Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 2057/Kol/2024 Assessment Year: 2017-2018 Nandan Live Stock Development Cooperative Society Limited,………………………….……..……Appellant C/O. Jain Vinod K & Associates, 41A, A.J.C. Bose Road, Diamond Prestige Nirman, 6Th Floor, Suite No. 613, Kolkata-700017 [Pan:Aaaan5417B] -Vs.- Assistant Commissioner Of Income Tax,...Respondent Circle-1, Durgapur, Aayakar Bhawan, City Centre, Durgapur-734101, West Bengal Appearances By: Shri Vinod Jain, A.R., Appeared On Behalf Of The Assessee Ms. Madhumita Das, Addl. Cit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: February 24, 2025 Date Of Pronouncing The Order: May 06, 2025 O R D E R

Section 142(1)Section 143(2)Section 68Section 80P(2)

afresh, which were filed by way of paper book especially from pages no. 119 to 143 with a direction to provide 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

Evershine No II Co-Op Hsg So Limited, Mumbai vs. ITO Ward 25(1)(1), Mumbai

The appeal of the appellant is allowed

ITA 819/MUM/2025[2014-15]Status: DisposedITAT Mumbai06 May 2025AY 2014-15

Bench: Smt. Beena Pillai, Jm & Shri Omkareshwar Chidara, Am

For Appellant: Shri Bhupendra ShahFor Respondent: Shri Pravin Salukhe

Section 143(1)Section 154Section 234ASection 80P(2)(d)

condonation filed and by also overlooking the fact that debatable addition cannot be sustained u/s 154 or 143[1] and not granting an opportunity of being heard before passing the order.” 2. The Ld. AR of the appellant has made two fold argument before the ITAT as follows

Savita Homemakers LLP, Mumbai vs. Assistant Commissioner of Income Tax, Mumbai

Appeal of the assessee is allowed

ITA 2849/MUM/2024[2014-15]Status: DisposedITAT Mumbai06 May 2025AY 2014-15

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Appellant: Shri Piyush Chhajed & Shri AyushFor Respondent: Shri Rakesh Ranjan- CIT-DR

Section 143(3)Section 147Section 263Section 69C

erroneous in so far as it is prejudicial to the interests 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 of the case justify

Egis India Consulting Engineers Private Limited, Delhi vs. Deputy Commissioner of Income Tax, Circle 1, Faridabad

In the result, the appeal is allowed for statistical purposes

ITA 384/DEL/2024[2017-18]Status: DisposedITAT Delhi06 May 2025AY 2017-18

Bench: Shri M. Balaganesh & Shri Vimal Kumaregis India Consulting Engineers Vs. Dcit, Pvt. Ltd, Circle-1, Faridabad T-305, Tf, Tirupati Plaza, Sector-Xi (Mlu), Pocket 4, Plot No. 11, Dwarka, New Delhi (Appellant) (Respondent) Pan: Aaccb6390F Assessee By : Shri Manuj Sabharwal, Adv Shri Drona Negi, Adv Shri Devvrat Tiwari, Adv Revenue By: Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 03/03/2025 Date Of Pronouncement 03/03/2025

For Appellant: Shri Manuj Sabharwal, AdvFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR

Section 143(1)Section 250Section 250(4)Section 43B

issues raised before the ld JCIT(A) in the original ground. Needless to mention that the assessee be given reasonable opportunity of being heard. The assessee is at liberty to furnish fresh evidences, if any, in support of its contentions. The assessee is directed to cooperate with the ld JCIT

Hridaan Enterprise, Dumka vs. ITO, Dumka

In the result, the grounds of appeal raised by the assessee are allowed for statistical purposes

ITA 262/RAN/2024[2017-18]Status: DisposedITAT Ranchi05 May 2025AY 2017-18

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay(Virtual Hearing) Hridaan Enterprises, I.T.O., Bhagalpur Road, Dumka. Dumka. Vs. Pan No. Aajfh 3035 R Appellant/ Assessee Respondent/ Revenue

Section 115BSection 68

Authority (JHALSA), Ranchi. Needless to direct that before passing the order, 3 Hridaan Enterprises Vs ITO the ld. CIT(A) shall grant reasonable opportunity of being heard to the assessee. The assessee is also directed to avail this opportunity and not to cause further delay and seek adjournment without

Nand Kumar Singh, Adityapur vs. DCIT ACIT Circle 2 Jsr, Jamshedpur

In the result, the grounds of appeal raised by the assessee are allowed for statistical purposes

ITA 234/RAN/2024[2012-13]Status: DisposedITAT Ranchi05 May 2025AY 2012-13

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 144Section 147

fact that assessment was completed under section 144 of the Act, to pass assessment order afresh in accordance with law. grant reasonable opportunity of being heard to the assessee. The assessee is also directed to avail this opportunity and not to cause further delay and seek adjournment without any valid

Nand Kumar Singh, Adityapur vs. Dcitacit Circle 2, Jamshedpur

In the result, the grounds of appeal raised by the assessee are allowed for statistical purposes

ITA 233/RAN/2024[2011-12]Status: DisposedITAT Ranchi05 May 2025AY 2011-12

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahay

Section 144Section 147

Shree Loladi Mataji Madh Trust, Gandhidham vs. Pr. CIT(Exemption), Ahmedabad

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

ITA 836/RJT/2024[2024-25]Status: DisposedITAT Rajkot05 May 2025AY 2024-25

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./I.T.A. No.836/Rjt/2024 (िनधा"रण वष" / Assessment Year : -Na-) Shree Loladi Mataji Madh बनाम/ The Pr.Cit (Exemptions) Trust Ahmedabad – 380 015 Vs. Shinay, Vagamshi Faliya Shinay Gandhidham – 370 205 (Gujarat) "ायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aayts 3998 R (अपीलाथ" /Appellant) (""थ" / Respondent) .. Assessee By : Shri Mehul Ranpura, Ld.Ar Revenue By : Shri Sanjay Punglia, Ld. Cit(Dr) सुनवाई की तारीख / Date Of Hearing 12 /02/2025 घोषणा की तारीख /Date Of Pronouncement 05/05/2025 आदेश / O R D E R Per Dinesh Mohan Sinha: This Appeal By The Assessee Is Directed Against The Order Passed By The Ld. Commissioner Of Income Tax (Exemption), Ahmedabad [Hereinafter Referred To As “Cit(E)”], Dated 02/09/2024, Rejecting The Application For Registration Under Section 12Ab Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”).

For Appellant: Shri Mehul Ranpura, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld. CIT(DR)

Section 10(230)Section 12A

claim. At the same time, the Ld. CIT(E) shall decide the matter on merits and in accordance with law, after granting due opportunity of being heard. The assessee may also be permitted to make necessary correction in the application in Form No.10AB under sub-clause (iii) of clause

Md. Shanawaj Rizwi, Purnea vs. ACIT, CC-2, Patna

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

ITA 560/PAT/2024[2017-18]Status: DisposedITAT Patna05 May 2025AY 2017-18

Bench: The Ld. Cit(A) Where Also He Could Not Succeed & The Addition Was Confirmed.

Section 133Section 147Section 148Section 250Section 56(2)(vii)

that the Ld. CIT(A) has erred in passing order dismissing the appeal without merit and without affording proper opportunity of being heard to the appellant and had violated the principles of equity, natural justice and fair play which requires proper and adequate opportunity of being heard. 03. For that ... there is any amount surviving for treatment u/s 56(2)(vii) of the Act. Needless to say, the Ld. AO will provide ample opportunity of being heard and the assessee would do well to present all documents before the Ld. AO. The assessee is also at liberty to raise

Roshan Lal, Alwar vs. Income Tax Officer, Bhiwadi

Appeal of the assessee is allowed for

ITA 50/JPR/2025[2014-15]Status: DisposedITAT Jaipur05 May 2025AY 2014-15

Bench: The Hon'Ble Income Tax Appellate Tribunal, Jaipur.

For Appellant: Sh. Prateek BasotiaFor Respondent: Sh. Anoop Singh, Addl. CIT

Section 142(1)Section 147Section 148Section 151(1)Section 69A

ITAT. 18. This appeal has been filed as the assessment order, being ex-parte and passed without affording the Appellant an opportunity to be heard, is unsustainable in law and merits reconsideration in the interest of justice. 19. The Learned Assessing Officer further erred in charging interest under 13 Roshal ... aside the case to the file of the ld. AO to decide the case of the assessee on merits after giving proper opportunity of being heard to the 27 Roshal Lal vs. ITO assessee. At the same time, the assessee is directed to represent and present all the facts before

Sushila Devi Jangid, Jaipur vs. ITO, WD 7(2), Jaipur

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

ITA 374/JPR/2025[2010-11]Status: DisposedITAT Jaipur05 May 2025AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकरअपीलसं. / ITA. No. 374/JP/2025 निर्धारणवर्ष / AssessmentYears : 2010-11 Smt. Sushila Devi Jangid 65, Koshaliya Vihar Hajyawala,Muhana Mandi Ke Pass, Sanganer, Jaipur 302 029 बनाम Vs. The ITO Ward 7(2) Jaipur अपीलार्थी / Appellant प्रत्यर्थी / Respondent स्थायीलेखा सं. / जीआईआरसं./PAN/GIR No.: AFMPJ 2091 P निर्धारिती की ओरसे / Assesseeby : Shri Utkarsh Mishra, Advocate राजस्व की ओरसे / Revenue by :Shri Gautam Sing

For Appellant: Shri Utkarsh Mishra, AdvocateFor Respondent: Shri Gautam Singh Choudhary, Addl.CIT -DR a

Section 142(1)Section 147Section 250

referred to as ‘CIT(A)’) passed u/s 250 dated 10.01.2025. SUBMISSION 1. GROUND NO. 1: Best Judgement Assessment in the absence of adequate opportunity of being heard is unjust 2. he revenue in the instant case has erred in not providing adequate opportunity of being heard to the assessee, especially ... person against whom any action is sought to be taken and his right or interest is being affected, shall be given an equal opportunity of being heard and defend himself. 5. It gives right to the party to respond to the evidence against them and to choose legal representative

Shri Agrasen Shikha Prasar Samiti, Mahwa vs. CIT Exemption, Jaipur

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

ITA 351/JPR/2025[2025-26]Status: DisposedITAT Jaipur05 May 2025AY 2025-26

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

For Appellant: Shri Shrawan Kumar Gupta, AdvocateFor Respondent: Shri Rajesh Ojha, CIT-DR &

Section 12ASection 80G

Impugned order u/s 12AB of the Act dated 25.12.2024 is bad in law and on facts, without providing adequate & reasonable opportunity of being heard, being without jurisdiction and for various other reasons and hence the same may kindly be quashed. 2. The Ld. CIT(E) erred in law as well ... Impugned order u/s 80G/10AB of the Act dated 25.12.2024 is bad in law and on facts, without providing adequate & reasonable opportunity of being heard, being without jurisdiction and for various other reasons and hence the same may kindly be quashed. 2. The Ld. CIT(E) erred in law as well