“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

Arjun Singh Meena, Jaipur vs. Income Tax Officer, Jaipur

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

ITA 42/JPR/2025[2010-11]Status: DisposedITAT Jaipur17 Apr 2025AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. Yogesh Kumar Sharma, AdvFor Respondent: Sh. Gautam Singh Choudhary, JCIT

Section 144

regard to procedural aspect, they are taken together for adjudication. These are general grounds taken by the appellant with regard to lack of opportunity of being heard during the assessment proceedings and non-service of notice. Notwithstanding the fact that these are totally unsubstantiated claims, there is nothing on record ... view that the lis between the parties must be decided on merits so that nobody’s rights could be scuttled down without providing opportunity of being heard to the assessee. Considering that aspect of the matter we admit the additional evidence on record and set aside the matter

Shree Pa Digamber Jain Sahitya Shodh Sansthan, Bhilwara vs. CIT, Exemption, Jaipur

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

ITA 150/JPR/2025[2025-26]Status: DisposedITAT Jaipur17 Apr 2025AY 2025-26

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

For Appellant: Shri Sunil Porwal, C.A. (Thru: VC)For Respondent: Shri Arvind Kumar, CIT-DR

Section 10Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)(iv)

course of hearing, the ld. AR of the assessee in both the appeals mainly submitted that the assessee was not provided adequate opportunity of being heard by the ld. CIT(E) and thus both the orders should be quashed being against the principles of natural justice. Further ... trust in deciding the eligibility of the assessee trust for grant of registration u/s 12AB of the Act. 11. Needless to say, reasonable opportunity of being heard and liberty to furnish necessary information / explanations / documents / evidence shall be afforded to the assessee in the set aside proceedings. 12. The assessee

Shree Pa Digamber Jain Sahitya Shodh Sansthan, Bhilwara vs. CIT Exemption, Jaipur

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

ITA 149/JPR/2025[2025-26]Status: DisposedITAT Jaipur17 Apr 2025AY 2025-26

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

For Appellant: Shri Sunil Porwal, C.A. (Thru: VC)For Respondent: Shri Arvind Kumar, CIT-DR

Section 10Section 12ASection 12A(1)(ac)Section 80GSection 80G(5)(iv)

Pukhraj, Bharatpur vs. Income Tax Officer, WD-1, Bharatpur

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

ITA 1114/JPR/2024[2011-12]Status: DisposedITAT Jaipur17 Apr 2025AY 2011-12

Bench: Dr. S. Seethalakshmi & Shri Gagan Goyalpukhraj, C/O. Virendra Singh Gothiya, Atal Bandh Gate, Dhau Pyasa, Bharatpur 321 001 Pan No.: Birpp 6009G ...... Appellant Vs. Income Tax Officer Ward-1, Bharatpur ...... Respondent

For Appellant: Mr. Sankalp Pitaliya, CA, Ld. ARFor Respondent: Mr. Gautam Singh Choudhary, JCIT- Ld. DR

Section 148Section 250

restore the matter back to the JAO for fresh consideration of the assessee’s claim for balance 8 Lacs after giving a fresh opportunity of being heard following the procedure laid down in section 282 of the Act for service of notice and the assessee is directed to appear before

Akhilesh Kumar Singh, Barabanki vs. Income Tax Officer5(4), Barabanki

In the result, the appeal of the assessee is dismissed

ITA 75/LKW/2025[2017-18]Status: DisposedITAT Lucknow17 Apr 2025AY 2017-18

Bench: SHRI ANADEE NATH MISSHRA (Accountant Member)

For Appellant: NoneFor Respondent: Shri Sanjeev Krishna Sharma, Addl

Section 115BSection 69A

circumstance of the case, the order of Assessment has been passed in absolute violation of the principles of Natural Justice, without providing adequate opportunity of being heard and therefore deserves to be declared a nullity. 6. The appellant craves for leave to add, modify, amend or delete any other

M/S. Dholera Realcon LLP, Ahmedabad vs. The ITO, Ward-3(2)(1), Ahmedabad

In the result, the appeal filed by the Assessee is allowed for statistical purpose

ITA 1545/AHD/2024[2017-18]Status: DisposedITAT Ahmedabad17 Apr 2025AY 2017-18

Bench: DR. BRR KUMAR (Vice President), Shri T.R. SENTHIL KUMAR (Judicial Member)

Section 115BSection 133(6)Section 147Section 148Section 271ASection 68Section 69

confirmed order passed by the Income Tax Officer, NFAC(Assessment)- Delhi. The appellate authority has dismissed the appeal without giving proper opportunity of being heard to the appellant. Hence the same being against the principle of natural justice and law required to be quashed. 2. The Ld. Commissioner of Income ... grievously erred in law while passing the order without providing proper and statutory time period to submit the documents reply and proper opportunity of being heard. Hence, the entire proceedings may please be considered as in gross violation of principle of natural justice. 10. The Ld. Assessing Authority has grievously

ACIT, Circlle-34, Kolkata vs. Subhas Kumar Kedia, Kolkata

In the result, appeal of the revenue is dismissed

ITA 1677/KOL/2024[2016-17]Status: DisposedITAT Kolkata17 Apr 2025AY 2016-17

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.1677/Kol/2024 (नििाारण वर्ा / Assessment Year : 2016-2017) Acit, Circle-34, Kolkata Vs Subhas Kumar Kedia, 41, N.S.Road, Kolkata Pan No. :Afnpk 9669 M (अपीलार्थी /Appellant) (प्रत्यर्थी / Respondent) .. नििााररती की ओर से /Assessee By : Ms. Shreya Loyalka, Ar राजस्व की ओर से /Revenue By : Shri P.N.Barnwal, Cit-Dr सुनवाई की तारीख / Date Of Hearing : 21/01/2025 घोषणा की तारीख/Date Of Pronouncement : 17/04/2025 आदेश / O R D E R Per Rajesh Kumar, Am : This Is An Appeal Filed By The Revenue Against The Order Dated 05.06.2024, Passed By The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2016-2017, On The Following Grounds Of Appeal :- I) That On The Facts & In The Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order U/S.148A(D) & All Subsequent Proceedings. Ii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Failed To Acknowledge The Fact That The Assesse Had Not Expressed Any Grievance Against The Validity Of Order U/S 148A(D) By Moving Any Writ Petition Which Should Have Been Done In Case Of Any Grievance After Getting The Sald Order U/S.148A(D). Iii) That On The Facts & Circumstances Of The Case, The Ld. Cit(Appeals), Nfac, Delhi, Erred In Quashing The Order When The Ld. Cit(A) Has No Jurisdiction To Deal With The Question Whether The 148A(D) Order Was Passed Validly Or Properly As An Order U/S.148A(D) Is Not An Appealable Order Before Ld. Cit(A) As Per Section 246A.

For Appellant: Ms. Shreya Loyalka, ARFor Respondent: Shri P.N.Barnwal, CIT-DR

Section 148Section 148ASection 149Section 151Section 246ASection 3Section 69A

assailed the AO for making an addition of Rs. 75,60,00,000/- by incorrectly invoking section 69A, without providing an opportunity of being heard before proposing variation, adding the loan transaction as income, not providing the complete report of DDIT (Inv.), not providing the details of alleged transactions, without ... Mahes Gulbrai Joshi v. CIT, (2005) 95 ITD 300 (Mumbai)(SMC), Sona Electric Co. v. СІТ. (1984) 19 Такman 160 (Delhi) to proper opportunity of being heard The show cause notice proposing variations has been signed on 19 May 2023 at 22:41 hours and with no working days

Mridula Healthcare (P) Ltd, New Delhi vs. ITO, Ward-17(4), New Delhi

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

ITA 63/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Apr 2025AY 2017-18

Section 115BSection 143(3)Section 68Section 69A

matter may be restored to the file of Ld. First Appellate Authority for decision afresh in accordance with law after affording an opportunity of being heard to the assessee. 8. Ld. DR relied on the orders of the authorities below. 9. I have heard the rival submissions made ... issue to the file of the Ld. CIT(A) for consideration of the issue afresh by passing a reasoned order, upon granting an opportunity of being heard to the assessee and upon considering the evidence on record or any other evidence which the assessee may choose to file

Narendra Singh, Budaun vs. ITO, Ward-2(3), Budaun

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

ITA 40/DEL/2025[2013-14]Status: DisposedITAT Delhi17 Apr 2025AY 2013-14

Bench: the AO who was constrained to complete the assessment ex parte. In appeal before the Ld. First Appellate Authority also the assessee did not appear and the learned CIT(A) also decided the appeal ex parte, qua the assessee. He submitted that before this Tribunal also the assessee has not cared to appear at the time of hearing which shows that the assessee is not interested to pursue the appeal. He supported the orders of the authorities below.

Section 144Section 147Section 44A

being heard and thus remit the issue to the file of Ld. Assessing Officer to finalize the assessment afresh upon granting adequate opportunity of being heard to the assessee and upon considering the evidence on record or any other evidence which the assessee may choose to file at the time

Sanjeev Maggu, Delhi vs. ITO Ward-49(1), Delhi

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

ITA 342/DEL/2025[2021-22]Status: DisposedITAT Delhi17 Apr 2025AY 2021-22

Bench: The Nfac The Assessee Had Filed Condonation Application, Supported By Affidavit, Explaining That The 2

Section 143(3)Section 144B

remitting the matter to the Ld. CIT(A), to decide the appeal on merits in accordance with law, upon granting adequate opportunity of being heard to the assessee and upon considering the evidence on 3 ITA 342/Del/2025 Sanjeev Maggu v. ITO record or any other evidence which the assessee

Rekha Yadav, Gurgaon vs. ITO Ward-5(1), New Delhi

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

ITA 336/DEL/2025[2012-13]Status: DisposedITAT Delhi17 Apr 2025AY 2012-13

Bench: DELHI BENCH “SMC”: NEW DELHI Ms. MADHUMITA ROY (Judicial Member)

Section 144Section 147Section 69Section 69A

prayed that the matter be remitted to the file of the Ld. CIT(A) for decision afresh on merit upon granting adequate opportunity of being heard to the assessee. 5. Learned DR supported the orders of authorities below. 6. I have heard the rival submissions and perused the materials available ... remit the issue to the Ld.CIT(A) for consideration of the issue afresh by passing a reasoned order upon granting an opportunity of being heard to the assessee and upon considering the evidence on record or any other evidence which the assessee may choose to file at 5 Rekha Yadav

The Centre for Applied Social Sciences, Delhi vs. ITO(Exmp) 2.1, Delhi

In the result, the appeal filed by the Appellant is partly allowed for

ITA 4693/DEL/2024[2024-25]Status: DisposedITAT Delhi17 Apr 2025AY 2024-25

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandrathe Centre For Applied Vs. Ito (Exemption) 2.1 Social Sciences Ward Exemption 2(1), 30-C, Ground Floor, Ram Civic Centre, Nagar Extension, Krishna New Delhi Nagar, Delhi Pan: Aaett5910A

Section 11Section 12(1)(ac)Section 12ASection 12A(1)(b)Section 2(15)

Centre for applied Social Science Vs. ITO documents produced by the Appellant and pass the order in accordance with law after providing opportunity of being heard to the Appellant. The Appellant is also at liberty to produce all the document as required by the Ld. CIT(E) to substantiate

Sangeeta Agrawal L.H of Late Sh. Rakesh Kumar Agrawal, Delhi vs. ACIT, Circle-60(1), New Delhi, Delhi

The Appeal of the Assessee is partly allowed for statistical purpose

ITA 4668/DEL/2024[2014-15]Status: DisposedITAT Delhi17 Apr 2025AY 2014-15

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwalsangeeta Agrawal L. H Of Vs. Acit Late Sh. Rakeshkuamr Circle-60(1) Agrawal, New Delhi Sangeeta Agrawal L/H Of Late Sh. Rakesh Kumar Agrawal, New Delhi Pan: Afipa6968A Appellant Respondent

Section 133(6)Section 143(3)

case of the Assessee that, it is not the duty of the Assessee to produce parties before the A.O. Thus, claimed that reasonable opportunity of being heard was not provided by the A.O. and the additional evidences could not be furnished before the A.O. during the assessment proceedings ... ACIT and the A.O. is also directed to consider those documents in accordance with law and frame the de-novo assessment after providing opportunity of being heard to the Assessee. 8. Since we have remanded the matter to the file of the A.O. for framing de-novo assessment, we refrain

Flex Foods Limited, New Delhi vs. DCIT Central Circle - 27, New Delhi

Appeal is allowed for statistical purposes

ITA 3025/DEL/2024[2018-19]Status: DisposedITAT Delhi17 Apr 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 M/S. Flex Foods Limited, Vs. Dcit, 305, Third Floor, Bhanot Central Circle-27, Corner, Pamposh Enclave, New Delhi Greater Kailash-1, New Delhi Pan: Aaacf0108K (Appellant) (Respondent) Assessee By Sh. M.P. Rastogi, Adv. Sh. Shivam Malik, Adv. Department By Sh. Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing 17.04.2025 Date Of Pronouncement 17.04.2025 Order

Section 10(1)Section 143(3)

assessee has raised the following substantive grounds in the instant appeal: “1. The Ld. CIT(A) did not provide a proper opportunity of being heard to Assessee to present the condonation of delay. 2. In the interest of justice, delay of (no, of days) should be condoned to the Assessee

Movex Services Pvt Ltd., Delhi vs. ITO, Ward-17(1), Delhi

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

ITA 1119/DEL/2023[2020-21]Status: DisposedITAT Delhi17 Apr 2025AY 2020-21

Bench: Shri Mahavir Singh & Shri M. Balaganeshmovex Services Pvt. Ltd, Vs. Ito, Flat No. T-6, Top Floor, K No. Ward-17(1), 506, Aravali Apartments, New Delhi Bypass Road, Mahipalpur Extension, Delhi (Appellant) (Respondent) Pan: Aahcm3390H

For Appellant: Shri R. S. Chaoudhan, CaFor Respondent: Shri Amit Katoch, Sr. DR

Section 143(1)Section 40A(3)

issue to the file of Learned NFAC for denovo adjudication in accordance with law. Needless to mention that the Assessee be given reasonable opportunity of being heard. The Assessee is directed to cooperate with the Learned NFAC for expeditious disposal of this appeal by not taking unwarranted adjournments except

Tupperware India Private Limited, New Delhi vs. DCIT, Circle-25(1), New Delhi

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

ITA 462/DEL/2022[2017-18]Status: DisposedITAT Delhi17 Apr 2025AY 2017-18

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Rohit Tiwari, AdvFor Respondent: Shri S. K. Jadav, CIT DR

Section 143(3)Section 144BSection 144CSection 144C(3)Section 92CSection 92F

same has been studied carefully and issues were discussed with the AR, After considering all the facts of the case and adequate opportunity of being heard duly provided to the Assessee including oral hearing, it was apparent that the license agreement signed by the assessee was only to transfer profit

Tupperware India Private Limited, New Delhi vs. ACIT, Circle-25(1), New Delhi

In the result, the appeal of the assessee for AY 2018-19 is partly allowed for statistical purposes

ITA 2409/DEL/2022[2018-19]Status: DisposedITAT Delhi17 Apr 2025AY 2018-19

Bench: Shri Mahavir Singh & Shri M. Balaganesh

For Appellant: Shri Rohit Tiwari, AdvFor Respondent: Shri S. K. Jadav, CIT DR

Section 143(3)Section 144BSection 144CSection 144C(3)Section 92CSection 92F

Jp Rice & Foods Pvt Ltd, New Delhi vs. ITO Ward -13(1), New Delhi

In the result, the appeal of the Assessee is partly allowed for

ITA 1722/DEL/2020[2016-17]Status: DisposedITAT Delhi17 Apr 2025AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandrajp Rice & Foods Pvt. Ltd. Vs. Ito 2717, Ff, Galipattey, Ward-13(1) Naya Bazar, New Delhi New Delhi Pan: Aaccji550D Appellant Respondent Assessee By Sh. Manu Gawri, Ca Revenue By Sh. Om Prakash, Sr. Dr Date Of Hearing 09/04/2025 Date Of Pronouncement 17/04/2025

Section 68

directed to consider the documents produced by the Assessee and decide the Appeal in accordance with law after providing opportunity of being heard to the Assessee. Ordered accordingly. 8. In the result, the appeal of the Assessee is partly allowed for statistical purpose. Order pronounced in the open court

Alagarsamy, Dindigul vs. DCIT, Ward-1, Dindigul

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

ITA 315/CHNY/2025[2017-18]Status: DisposedITAT Chennai17 Apr 2025AY 2017-18

Bench: Shri George George K., Vice- & Shri S.R. Raghunathaआयकरअपीलसं./Ita No.: 315/Chny/2025 िनधा"रणवष" / Assessment Year: 2017-18 Alagarsamy, Vs. The Deputy Commissioner Of 1, Anumantharayan Kottai, Income Tax, Dindigul – 624 001, Ward -1, Tamil Nadu. Dindigul. [Pan: Biqpa-6564-C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" कीओर से/ Appellant By : Shri A.G. Sathyanarayana Advocate ""थ"की ओर से/Respondent By : Shri A. Sasi Kumar, Cit सुनवाई की तारीख/ Date Of Hearing 20.03.2025 : घोषणा की तारीख /Date Of Pronouncement : 17.04.2025 आदेश /O R D E R Per S. R. Raghunatha: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Under Section 250 Of The Income Tax Act, 1961 [“Act” In Short] Dated 22.06.2024 Pertains To The Assessment Year 2017-18. 2. We Find That This Appeal Is Filed With A Delay Of 153 Days. The Assessee Filed A Petition For Condonation Of Delay Stating The Reasons. Upon Hearing Both The Parties & On Examination Of The Said Affidavit, We Find The Reasons Stated By The Assessee Are Bonafide, Which Really Prevented In :-2-:

For Appellant: Shri A.G. Sathyanarayana AdvocateFor Respondent: Shri A. Sasi Kumar, CIT

Section 142(1)Section 144Section 147rSection 148Section 250Section 69A

deem it proper to remand the matter to the file of the Assessing Officer to decide the issue afresh by affording one more opportunity of being heard to the assessee after considering the written submissions/documentary evidence as may be filed by the assessee to substantiate his claim. Thus, the grounds

Rahul Jesmin Seth, Chennai vs. ITO, Ncw-22(5), Tambaram

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

ITA 307/CHNY/2025[2017-18]Status: DisposedITAT Chennai17 Apr 2025AY 2017-18

Bench: Shri George George K., Vice- & Shri S.R. Raghunathaआयकर अपीलसं./Ita No.: 307/Chny/2025 िनधा"रण वष" / Assessment Year: 2017-18 Rahul Jesmin Seth, Vs. The Income Tax Officer, Flat No. Ef, 15Th Floor, Sapphire Non Corporate Ward –22(5), Block K, Olympia Opaline No. 33, Tambaram, Chennai. Omr Rajiv Gandhi Salai, Navallur, Chennai 603 103. [Pan: Bhsps-7395-L] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से/ Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri A. Sasi Kumar, Cit सुनवाई की तारीख/ Date Of Hearing 19.03.2025 : घोषणा की तारीख /Date Of Pronouncement : 17.04.2025 आदेश /O R D E R Per S. R. Raghunatha: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Under Section 250 Of The Income Tax Act, 1961 [“Act” In Short] Dated 23.12.2024 Pertains To The Assessment Year 2017-18. 2. The Assessee Raised 18 Grounds Of Appeal, Amongst Which, Besides Challenging The Exparte Order Of The Ld. Cit(A), The Assessee Also Agitated That The Ld. Cit(A) Is Not Justified In Confirming The Additions Of ₹.27,31,000/- Being The Cash Deposits Made In Sbns During The Demonetization Period

For Appellant: Shri N. Arjun Raj, AdvocateFor Respondent: Shri A. Sasi Kumar, CIT

Section 10Section 10(14)(ii)Section 133(6)Section 139(1)Section 142(1)Section 144Section 17(2)Section 250Section 69

neither willful nor wanton, but, due to circumstances beyond his control, and prayed that the assessee may be afforded one more opportunity of being heard to the assessee to substantiate his case before the Assessing Officer. 7. The ld. DR Shri A. Sasi Kumar, CIT opposed the same and drew ... deem it proper to remand the matter to the file of the Assessing Officer to decide the issue afresh by affording one more opportunity of being heard to the assessee after considering the written submissions/ documentary evidence as may be filed by the assessee to substantiate his claim. Thus