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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

Shree Khodiyar Gau Seva Yuvak Mandal Charitable Trust, Jamnagar vs. The CIT(Exm.), Ahmedabad

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

ITA 96/RJT/2024[2023-24]Status: DisposedITAT Rajkot01 May 2025AY 2023-24

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./I.T.A. No.96/Rjt/2024 (िनधा"रण वष" / Assessment Year : 2023-24) Shree Khodiyar Gau Seva बनाम/ The Cit (Exemption) Yuvak Mandal Charitable Ahmedabad – 380 015 Vs. Trust Moti Veraval, Tal. Lalpur Dist. Jamnagar – 361 012 "ायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaxts 8749 R (अपीलाथ" /Appellant) (""थ" / Respondent) .. Assessee By : Ms. Amoli Gusani, Ld.Ar Revenue By : Shri Sanjay Punglia, Ld.Cit-Dr

For Appellant: Ms. Amoli Gusani, Ld.ARFor Respondent: Shri Sanjay Punglia, Ld.CIT-DR
Section 11Section 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

Vinod Kumar Jangir, Jhunjhunu vs. Dct, Circle (Intl Tax), Jaipur

Appeal is allowed and the impugned assessment

ITA 779/JPR/2024[2013-14]Status: DisposedITAT Jaipur01 May 2025AY 2013-14

Bench: Shri Gagan Goyal & Shri Narinder Kumarmr. Vinod Kumar Jangir, C/O. Yashi Super Market, Vishwakarma Complex, Gandhi Chowk, Distt. Jhunjhunu -333001 Pan No. Arzpj 7960G ...... Appellant Vs.

For Appellant: Mr. R. S. Poonia, C.A., Ld. ARFor Respondent: Mrs. Alka Gautam, CIT, Ld. DR
Section 139(4)Section 144CSection 147Section 148Section 148ASection 69

approval of specified authority, with respect to the information which suggests that the income chargeable to tax has escaped assessment; (ii) provide an opportunity of being heard to the assessee, with the prior approval of specified authority; (iii) consider the reply of the assessee furnished, if any, in response

Income Tax Officer, Ward 2(1), Kota vs. Ram Lal and Sons, Kota

In the result, grounds taken by the Revenue are allowed for statistical purposes

ITA 408/JPR/2024[2017-18]Status: DisposedITAT Jaipur01 May 2025AY 2017-18

Bench: Shri Gagan Goyal & Shri Narinder Kumarito, Ward 2(1), Kota. ...... Appellant Vs.

For Appellant: NoneFor Respondent: Mrs. Swapnil Parihar, JCIT, Ld. DR
Section 133(6)Section 142(1)Section 147Section 148Section 194HSection 250Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL JAIPUR BENCH “B”, JAIPUR BEFORE SHRI GAGAN GOYAL, ACCOUNTANT MEMBER AND SHRI NARINDER KUMAR

The Talwandi Rai Multipurpose Agriculture Cooperative Society Limited, Talwandi Rai vs. Income Tax Officer, Ward-2, Jagraon

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

ITA 852/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh01 May 2025AY 2017-18

Bench: Sh. Rajpal Yadav, Hon’Ble Vice- & Sh. Krinwant Sahay, Hon’Ble(Hybrid Hearing) I.T.A. Nos. 852 & 1024 /Chandi/2024 Assessment Year: 2017-18

Section 143(3)Section 144Section 249(3)Section 250Section 68Section 80P(2)(a)

claim and prove his case. I.T.A. Nos. 852 & 1024 /Chandi/2024 6 Assessment Year: 2017-18 6.2 The assessee should be provided reasonable opportunity of being heard and the assessee shall fully cooperate in appellate proceedings, for proper disposal of case on merits. 6.3 Since we have decided the appeal

The Talwandi Rai Multipurpose Agriculture Coperative Society Ltd, Vpo. Talwandi Rai vs. Income Tax Officer, Ward-2, Jagraon

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

ITA 1024/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh01 May 2025AY 2017-18

Bench: Sh. Rajpal Yadav, Hon’Ble Vice- & Sh. Krinwant Sahay, Hon’Ble(Hybrid Hearing) I.T.A. Nos. 852 & 1024 /Chandi/2024 Assessment Year: 2017-18

Section 143(3)Section 144Section 249(3)Section 250Section 68Section 80P(2)(a)

claim and prove his case. I.T.A. Nos. 852 & 1024 /Chandi/2024 6 Assessment Year: 2017-18 6.2 The assessee should be provided reasonable opportunity of being heard and the assessee shall fully cooperate in appellate proceedings, for proper disposal of case on merits. 6.3 Since we have decided the appeal

Shree Samprat Coop Hsg Soc Limited, Ahmedabad vs. Income Tax Officer Ward 3(3)(5), Ahmedabad

The appeal of the assessee is allowed for statistical

ITA 470/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad01 May 2025AY 2017-18

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokar

For Appellant: Shri Prashant Shrivastav, ARFor Respondent: Ms.Bhavnasingh Gupta, Sr.DR
Section 142(1)Section 143(2)Section 143(3)Section 57

file all relevant submissions in support of its claim. The learned CIT(A) shall ITA No.470/Ahd/2025 5 grant a reasonable opportunity of being heard and shall pass a speaking order in accordance with law. 8. In view of the above discussion, the order of the CIT(A) is set aside

Indus Alumni Association, Ahmedabad vs. The CIT(Exemption), Ahmedabad

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

ITA 2128/AHD/2024[NA]Status: DisposedITAT Ahmedabad01 May 2025

Bench: S/Shri T.R. Senthil Kumar

For Appellant: Shri S.N. Divatia, AR andFor Respondent: Adjournment Application
Section 10Section 12ASection 12A(1)Section 80GSection 80G(5)Section 80G(5)(iii)

fresh adjudication of the assessee’s application under section 80G(5)(iii), in accordance with law and after affording due opportunity of being heard. 8. In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced in the Court on 1*t May, 2025 at Ahmedabad

Prithviraj Sanwatraj Kankariya (HUF), Ahmedabad vs. The PCIT, Ahmedabad -1, Ahmedabad

In the result, appeal of the assessee is allowed

ITA 1786/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad01 May 2025AY 2017-18

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year: 2017-18

Section 144BSection 147Section 148Section 263

order passed by the Lrd. PCIT may please be held as in violation of principle of natural justice as no proper opportunity of being heard was given to the assessee before passing the order. Assessment Year: 2017-18 Prithviraj Sanwatraj Kankariya (HUF) vs. PCIT Page

ITO, Ward - 10(2), Kolkata vs. Astha Technical Services Ltd, Kolkata

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

ITA 20/KOL/2025[2014-15]Status: FixedITAT Kolkata01 May 2025AY 2014-15

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RAKESH MISHRA (Accountant Member)

For Appellant: Shri Sujit Basu, AdvocateFor Respondent: Shri Raja Sengupta, CIT-DR
Section 44A

justice, the issues in both the appeals appeal are restored to the file of Assessing Officer for readjudication after granting the assessee adequate opportunity of being heard. The assessee shall produce all such evidence, as if so desires, to substantiate its claim before the Assessing Officer when call

Sandeep Kumar Gupta, Kolkata vs. I.T.O., Ward - 29(1), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 2/KOL/2025[2017-2018]Status: DisposedITAT Kolkata01 May 2025AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.2/Kol/2025 Assessment Year: 2017-18 Sandeep Kr. Gupta ……………...……………………………..….……….Appellant 27/H/2, Gobra Gorasthan Road, Kolkata – 46. [Pan: Agspg8435F] Vs. Ito, Ward-29(1), Kolkata……..............................……........……...…..…..Respondent Appearances By: Shri Indranil Banerjee, Ar, Appeared On Behalf Of The Assessee. Shri Prabhakar Prakash Ranjan, Sr. Dr, Appeared On Behalf Of The Revenue. Date Of Concluding The Hearing : May 01, 2025 Date Of Pronouncing The Order : May 01, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 21.11.2023 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Outset, The Registry Has Informed That There Is A Delay Of 336 Days In Filing The Present Appeal. The Assessee Has Filed An Affidavit For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Find Reasonable Cause & Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case. 3. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Assessment Year 2017-18 By Declaring A Total Income Of Rs.7,63,000/-. The Case Of The Assessee Was Selected For Scrutiny Under

Section 133(6)Section 142(1)Section 143(2)Section 250

matter diligently and did not inform the assessee about the notice of hearing. As a result, the assessee was deprived of reasonable opportunity of being heard both before the Assessing Officer and ld. I.T.A. No.2/Kol/2025 Sandeep Kr. Gupta CIT(A). The ld. AR, therefore, prayed that the matter maybe remanded ... reexamine the issue afresh by considering all documents or evidences as submitted by the assessee in support of his case after granting reasonable opportunity of being heard to the assessee. The assessee is also directed to appear and cooperate in the proceedings and respond to notices as and when will

Kolkata Craft Combine Society, Kolkata vs. ITO, Ward-50(3), Kolkata

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

ITA 882/KOL/2024[2017-18]Status: DisposedITAT Kolkata01 May 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 115BSection 143(3)Section 250Section 69A

assessee for making the submission and to reframe the assessment de novo. Needless to say, the assessee shall be given a reasonable opportunity of being heard to make any further submission it wants to make in support of its grounds of appeal and shall not seek unnecessary adjournments. Accordingly

Naveen Commodeal Pvt. Ltd., Kolkata vs. ITO, Ward - 6(1), Kolkata

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

ITA 603/KOL/2024[2009-10]Status: DisposedITAT Kolkata01 May 2025AY 2009-10

Bench: Shri George Mathan & Shri Rakesh Mishraआयकर अपील सं/Ita No.603/Kol/2024 (निर्धारण वर्ा / Assessment Year : 2009-2010) Naveen Commodeal Pvt. Ltd. Vs Ito, Ward-6(1), Kolkata 184, 1St Floor, Lenin Sarani, Kolkata Pan No. :Aaccn 9633 P (अपीलधर्थी /Appellant) (प्रत्यर्थी / Respondent) .. निर्धाररती की ओर से /Assessee By : Shri Miraj D Shah, Ar रधजस्व की ओर से /Revenue By : Shri Susanta Shah, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 01/05/2025 घोषणा की तारीख/Date Of Pronouncement : 01/05/2025 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Dated 30.01.2024, Passed By The Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Passed In Din & Order No.Itba/Nfac/S/250/2023- 24/1060253423(1), For The Assessment Year 2009-2010. 2. Shri Miraj D Shah, Ar Appeared On Behalf Of The Assessee. Shri Susanta Shah, Sr. Dr Appeared On Behalf Of The Revenue. 3. It Was Submitted By The Ld Ar That The Ao Has Made Additions Without Considering The Relevant Documents Produced By The Assessee. It Was Submitted That In Appellate Proceedings, Though It Has Been Mentioned By The Ld. Cit(A) In Its Order That Notices Were Issued, However, The Same Have Not Been Served On The Assessee, Which Enabled The Assessee To Pursue The Matter Before The Ld. Cit(A), Resulting Into Dismissal Of The Appeal Of The Assessee. It Was, Thus, Submitted That The Matter May Be Restored To The File

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

this appeal are restored to the file of the ld. CIT(A) for readjudication the issues afresh after granting the assessee adequate opportunity of being heard. 6. In the result, appeal of the assessee is partly allowed for statistical purposes. Order dictated and pronounced in the open court on 01/05/2025

Sanjay Banik, Hooghly vs. I.T.O., Ward- 23(1), Hooghly

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

ITA 2352/KOL/2024[2013-2014]Status: DisposedITAT Kolkata01 May 2025AY 2013-2014

Bench: Shri George Mathan & Shri Rakesh Mishraआयकर अपील सं/Ita No.2351 To 2353/Kol/2024 (निर्धारण वर्ा / Assessment Year : 2012-13, 2013-14 & 2015-16) Sanjay Banik, Vs Ito, Ward-23(1), Hooghly 56, Stn Sarani, Po:Saradapally Ps : Bhadreswar, Hooghly Pan No. :Aegpb 3460 B (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररती की ओर से /Assessee By : Shri Soumitra Choudhury, Advocate रधजस्व की ओर से /Revenue By : Shri Susanta Shah, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 01/05/2025 घोषणा की तारीख/Date Of Pronouncement : 01/05/2025

For Appellant: Shri Soumitra Choudhury, AdvocateFor Respondent: Shri Susanta Shah, Sr. DR

issues in all the appeals to the file of Assessing Officer for adjudication afresh. Needless to say, the assessee shall be granted adequate opportunity of being heard. 3 ITA No.2351-2353/KOL/2024 7. In the result, all the three appeals of the assessee are partly allowed for statistical purposes. Order dictated

Sanjay Banik, Hooghly vs. I.T.O., Ward-23(1), Hooghly

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

ITA 2351/KOL/2024[2012-2013]Status: DisposedITAT Kolkata01 May 2025AY 2012-2013

Bench: Shri George Mathan & Shri Rakesh Mishraआयकर अपील सं/Ita No.2351 To 2353/Kol/2024 (निर्धारण वर्ा / Assessment Year : 2012-13, 2013-14 & 2015-16) Sanjay Banik, Vs Ito, Ward-23(1), Hooghly 56, Stn Sarani, Po:Saradapally Ps : Bhadreswar, Hooghly Pan No. :Aegpb 3460 B (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररती की ओर से /Assessee By : Shri Soumitra Choudhury, Advocate रधजस्व की ओर से /Revenue By : Shri Susanta Shah, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 01/05/2025 घोषणा की तारीख/Date Of Pronouncement : 01/05/2025

For Appellant: Shri Soumitra Choudhury, AdvocateFor Respondent: Shri Susanta Shah, Sr. DR

issues in all the appeals to the file of Assessing Officer for adjudication afresh. Needless to say, the assessee shall be granted adequate opportunity of being heard. 3 ITA No.2351-2353/KOL/2024 7. In the result, all the three appeals of the assessee are partly allowed for statistical purposes. Order dictated

Spring Marketing Pvt. Ltd., Kolkata vs. I.T.O., Ward - 7(1), Kolkata

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

ITA 1145/KOL/2024[2012-2013]Status: DisposedITAT Kolkata01 May 2025AY 2012-2013

Bench: Shri George Mathan & Shri Rakesh Mishraआयकर अपील सं/Ita No.1145/Kol/2024 (निर्धारण वर्ा / Assessment Year : 2012-2013) Spring Marketing Pvt. Ltd. Vs Ito-7(3), Kolkata 114/1A, Cotton Street, 1St Floor Burrabazar, Kolkata-700004 Pan No. :Aancs 0185 J (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्धाररती की ओर से /Assessee By : Shri Miraj D Shah, Ar रधजस्व की ओर से /Revenue By : Shri Susanta Shah, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 01/05/2025 घोषणा की तारीख/Date Of Pronouncement : 01/05/2025

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

issues in this appeal are restored to the file of the ld. AO for readjudication the issues afresh after granting the assessee adequate opportunity of being heard. The assessee is also directed to produce all the documentary evidence to substantiate his case during the course of readjudication proceeding before

Renisha Impex Private Limited, Mumbai vs. Assessing Officer, Nfau

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

ITA 1501/MUM/2025[2017-2018]Status: DisposedITAT Mumbai01 May 2025AY 2017-2018

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: NoneFor Respondent: Shri Ashok Kumar Ambastha, Sr. D/R &

file of the ld. CIT(A) with a direction to decide the appeals on merits of the case after affording reasonable and adequate opportunity of being heard to the assessee. 4. In the result, appeals of the assessee are allowed for statistical purposes. Order pronounced in the Court

Renisha Impex Private Limited, Mumbai vs. Assessing Officer, Nfau

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

ITA 1500/MUM/2025[2015-2016]Status: DisposedITAT Mumbai01 May 2025AY 2015-2016

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: NoneFor Respondent: Shri Ashok Kumar Ambastha, Sr. D/R &

file of the ld. CIT(A) with a direction to decide the appeals on merits of the case after affording reasonable and adequate opportunity of being heard to the assessee. 4. In the result, appeals of the assessee are allowed for statistical purposes. Order pronounced in the Court

Renisha Impex Private Limited, Mumbai vs. Assessing Officer, National Faceless Assessment Unit

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

ITA 1454/MUM/2025[2013-2014]Status: DisposedITAT Mumbai01 May 2025AY 2013-2014

Bench: Shri Saktijit Dey, Hon’Ble & Shri Narendra Kumar Billaiya, Hon’Ble

For Appellant: NoneFor Respondent: Shri Ashok Kumar Ambastha, Sr. D/R &

file of the ld. CIT(A) with a direction to decide the appeals on merits of the case after affording reasonable and adequate opportunity of being heard to the assessee. 4. In the result, appeals of the assessee are allowed for statistical purposes. Order pronounced in the Court

Apurva Natvar Parikh & Co. Pvt Ltd, Mumbai vs. The Principle Commissioner of Income Tax, Mumbai-6, Mumbai

In the result, the appeal of the assessee is

ITA 2646/MUM/2024[2018-19]Status: DisposedITAT Mumbai01 May 2025AY 2018-19

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Madhur Agarwal, ARFor Respondent: Dr. K.R. Subhash, (CIT-DR)
Section 143(3)Section 14ASection 263

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 ... Assessing Officer is erroneous in so far as it/s prejudicial to the interests of the Revenue, he may, after giving the assessee an opportunity of being heard and after making an enquiry pass an order modifying the assessment made by the Assessing Officer or cancelling the assessment and directing fresh

Progressive Shelters Private Limited, New Delhi vs. ITO, Ward-20(2), New Delhi

In the result, the assessee’s appeal is allowed for statistical purposes

ITA 3416/DEL/2024[2012-13]Status: DisposedITAT Delhi01 May 2025AY 2012-13

Bench: Shri Vijay Pal Rao, Hon’Ble & Shri Avdhesh Kumar Mishra

Section 115BSection 69A

Authorities below. The Ld. Sr. DR, drawing our attention to various Para Nos. of assessment order and impugned order, submitted that reasonable opportunities of being heard were provided to the appellant assessee by the Ld. AO and the Ld. CIT(A). However, the appellant assessee tactfully ensured non-compliance ... matter back to the file of the Ld. AO for de-novo consideration and passing the assessment order afresh after providing adequate opportunity of being heard to the appellant assessee. The appellant assessee, no doubt, shall ensure compliance and cooperate in remanded assessment proceedings. Accordingly, we ordered so. 7 Deepak