“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

Shambhu Kumar, Bihar Sharif vs. NFAC, Patna

The appeals of the assessee are allowed for statistical purposes

ITA 720/PAT/2024[2016-2017]Status: DisposedITAT Patna04 Feb 2025AY 2016-2017

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.720&721/Pat/2024 Assessment Years: 2016-17 & 2017-18 Shambhu Kumar…………………………………………..………….……Appellant Meharpar, Nalanda, Bihar Shariff, Bihar-803101. [Pan: Amzpk6211E] Vs. Nfac, Delhi…………..……....….….. ……………….........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit - Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 03, 2025 Date Of Pronouncing The Order : February 04, 2025 Order Per Sonjoy Sarma: The Captioned Appeals Have Been Preferred By The Assessee Against Separate Orders Passed By 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’) For Assessment Years 2016-17 & 2017-18 Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. No One Has Appeared On Behalf Of The Assessee In Spite Of Serving Notices For Hearing & The Tribunal Cannot Keep These Appeals Pending For Indefinite Time Due To Non-Representation. Therefore, In The Absence Of Any Authorised Representative Of The Assessee, We Proceed To Decide Both The Appeals With The Help Of Ld. Dr & Also Considering The Material Available On Record.

Section 147Section 148Section 250Section 250(6)

direction to 2 I.T.A. Nos.720&721/Pat/2024 Assessment Years: 2016-17 & 2017-18 Shambhu Kumar re-examine the issue on merits after providing reasonable opportunity of being heard to the assessee for submitting relevant details or documents to substantiate the claim of the assessee. We also emphasise that the assessee must

Virendra Yadav, Madhubani vs. Income Tax Officer Ward 3(1), Darbhanga

The appeal of the assessee is allowed for statistical purposes

ITA 248/PAT/2024[2016-17]Status: DisposedITAT Patna04 Feb 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.248/Pat/2024 Assessment Year: 2016-17 Virendra Yadav……..…………………………………………..………….……Appellant Mainapatti, Maheshbada Khajauli, Madhubani, Bihar-847228. [Pan: Agwpy8420E] Vs. Ito, Ward-3(1), Darbhanga.……....….….. ……………….........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit - Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 04, 2025 Date Of Pronouncing The Order : February 04, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order Dated 30.11.2022 Of The Acit, Circle-3, Darbh [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 373 Days In Filing The Present Appeal. The Assessee Filed An Application For Condonation Of Delay Stating Reasons For Such Delay. After Considering The Application, We Find Reasonable Cause Which Was Beyond The Control Of The Assessee & The Delay Was Not Intentional. We, Therefore, Condone The Delay In Filing The Appeal & Adjudicate The Appeal On Merits Of The Case. 3. No One Has Appeared On Behalf Of The Assessee In Spite Of Serving Notices For Hearing & The Tribunal Cannot Keep These Appeals Pending For Indefinite Time Due To Non-Representation. Therefore, In The Absence Of Any Authorised Representative Of The Assessee, We Proceed To Decide

Section 143(2)Section 144Section 250Section 250(6)

with a direction to re- 2 I.T.A. No.248/Pat/2024 Assessment Year: 2016-17 Virendra Yadav examine the issues on merits after providing reasonable opportunity of being heard to the assessee for submitting relevant details or documents to substantiate the claim of the assessee. We also emphasise that the assessee must fully

Manish Kumar, Patna vs. Dc Ac Circle 4, Patna

The appeal of the assessee is allowed for statistical purposes

ITA 247/PAT/2024[AY 2017-2018]Status: DisposedITAT Patna04 Feb 2025

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.247/Pat/2024 Assessment Year: 2017-18 Manish Kumar, Patna…………………………………………..………….……Appellant Nav Chetna Path, Anishabad, Beur Path, Chitkohra, Bihar-800002.. [Pan: Avbpk7282L] Vs. Dc/Ac, Circle-4, Patna……..……....….….. ……………….........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit - Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 04, 2025 Date Of Pronouncing The Order : February 04, 2025 Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against An Order 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’) For Assessment Year 2017-18. 2. No One Has Appeared On Behalf Of The Assessee In Spite Of Serving Notices For Hearing & The Tribunal Cannot Keep These Appeals Pending For Indefinite Time Due To Non-Representation. Therefore, In The Absence Of Any Authorised Representative Of The Assessee, We Proceed To Decide The Appeal With The Help Of Ld. Dr & Also Considering The Material Available On Record. 3. Brief Facts Of The Case Are That The Assessee Is An Individual & Filed His Return Of Income On 04.11.2017 Declaring Total Income Of Rs.30,73,750/- For The Assessment Year 2017-18. The Case Of The Assessee Was Selected For Scrutiny Under Cass For The Reason “Large Cash Deposit During Demonetization & Abnormal Increase In Sales With

Section 143(2)Section 144Section 250Section 250(6)Section 69A

issue back to the file of the ld. CIT(A) with a direction to re-examine the issues on merits after providing reasonable opportunity of being heard to the assessee for submitting relevant details 2 I.T.A. No.247/Pat/2024 Assessment Year: 2017-18 Manish Kumar, Patna or documents to substantiate the claim

Sarlaben Dahyabhai Patel, Surat vs. Income Tax Officer, Ward - 2(2)(4), Surat

In the result, this ground is allowed for statistical purposes

ITA 558/SRT/2023[2014-15]Status: DisposedITAT Surat04 Feb 2025AY 2014-15

Bench: Shri Pawan Singh & Shri Bijayananda Pruseth

Section 254(1)Section 50CSection 54BSection 54FSection 55A

deduction under section 54F of the Act. Needless to direct that before passing the order, Assessing Office shall grant fair and reasonable opportunity of being heard to asses. In the result, this ground is allowed for statistical purposes 17. In the result, the appeal of the assessee is partly allowed

Nilesh Kiran Dhote, Amravati vs. ITO Ward-3, Amravati

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

ITA 594/NAG/2024[2020-21]Status: DisposedITAT Nagpur04 Feb 2025AY 2020-21

Bench: Shri V. Durga Rao

For Appellant: Shri Anurag Lakhotia, C.AFor Respondent: Shri Abhay Y. Marathe, Sr. DR

Section 143(1)Section 154Section 250Section 250(6)

matter may be sent back to the file of learned CIT(A) for deciding the issue on merits, by providing adequate opportunity of being heard to the assessee, in the interest of substantial justice. 5. The Learned DR on the other hand relied on the orders of the authorities below ... remit the matter in issue back to the file of learned CIT(A) for his afresh adjudication on merits, by affording adequate opportunity of being heard to the 5 ITA.No.594/NAG./2024 assessee. Needless to say, it is the sole responsibility of the assessee to plead and prove his case

Rusibrai Rajendra Surana, Chandrapur vs. ITO Ward-2, Chandrapur

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

ITA 589/NAG/2024[2020-21]Status: DisposedITAT Nagpur04 Feb 2025AY 2020-21

Bench: Shri V. Durga Rao

For Appellant: Shri K.P. Dewani, AdvocateFor Respondent: Shri Abhay Y. Marathe, Sr. DR

Section 143(1)Section 154Section 250Section 250(6)Section 90

file of jurisdictional Assessing Officer to verify the taxes paid by the assessee at Canada of Rs.8,28,090/-, by providing adequate opportunity of being heard to the assessee, in the interest of substantial justice. Otherwise, the assessee would be put to irreparable hardship and burdened with double taxes ... issue for afresh verification by the jurisdictional Assessing Officer and decide the matter in issue on merits in consequential proceedings, by affording adequate opportunity of being heard to the assessee. Accordingly, the grounds raised by the assessee are allowed for statistical purposes. I hold and direct accordingly

Ramesh Harishankar Tiwari, Nagpur vs. ITO, Ward 2, Chandrapur

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

ITA 587/NAG/2024[2021-22]Status: DisposedITAT Nagpur04 Feb 2025AY 2021-22

Bench: Shri V. Durga Rao

For Appellant: Shri Umang AgrawalFor Respondent: Shri Abhay Y. Marathe, Sr. DR

Section 10Section 10(10)(i)Section 142(1)Section 143(3)Section 250(6)

matter in issue back to the file of learned CIT(A) with a direction the decide the appeal on merits, by affording adequate opportunity of being heard to the assessee. Needless to say, it is the assessee’s sole risk and responsibility to plead and prove his case in consequential

Nana Aatmaramsa Ujwane, Akola vs. ITO Ward-3, Akola

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

ITA 586/NAG/2024[2017-18]Status: DisposedITAT Nagpur04 Feb 2025AY 2017-18

Bench: Shri V. Durga Rao

For Appellant: Shri K.P. Dewani, AdvocateFor Respondent: Shri Abhay Y. Marathe, Sr. DR

Section 143(1)Section 143(1)(a)Section 250(6)

filing the appeal before the learned CIT(A) and direct the learned CIT(A) to decide the appeal on merits, by affording adequate opportunity of being heard to the assessee. Needless to say, it is the assessee’s sole risk and responsibility to plead and prove his case in consequential

Ashish Tarunkumar Doshi, Yavatmal vs. ITO Ward-1, Yavatamal

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

ITA 585/NAG/2024[2016-17]Status: DisposedITAT Nagpur04 Feb 2025AY 2016-17

Bench: Shri V. Durga Rao & Shri Khettra Mohan Roy

For Appellant: Shri P.M. Gandhi, C.AFor Respondent: Shri Abhay Y. Marathe, Sr. DR

Section 139(1)Section 142(1)Section 144Section 147Section 148Section 250(6)Section 69

ITA.No.585/NAG./2024 file of learned CIT(A) with a direction to re-decide the matter in issue, after providing adequate opportunity of being heard to the assessee, subject to payment of Rs.10,000/- to the Legal Aid Authority of High Court of Bombay Bench of Nagpur. In the event

Madhav Gandhe Foundation, Nagpur vs. ITO Ward-1, Exemp, Nagpur

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

ITA 582/NAG/2024[2022-23]Status: DisposedITAT Nagpur04 Feb 2025AY 2022-23

Bench: Shri V. Durga Rao

For Appellant: Shri Abhay Agrawal, AdvocateFor Respondent: Shri Sandipkumar Salunke, CIT-DR

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

approval u/sec.80G(5) may be sent back to the file of learned CIT(E) for afresh adjudication with a direction to provide adequate opportunity of being heard to the assessee to substantiate it’s case. 5. The Learned DR did not object to the factual position. 4 ITA.No.582/NAG./2024 ... approval u/sec.80G(5) of the Act back to the file of learned CIT(E) for his afresh adjudication on merits, after providing adequate opportunity of being heard to the assessee. Accordingly, the appeal of the assessee is allowed for statistical purposes. 7. In the result, appeal of the assessee society

Priyanka Nitin Chandawar, Nagpur vs. Income Tax Officer Ward-1, Chandrapur

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

ITA 574/NAG/2024[2016-17]Status: DisposedITAT Nagpur04 Feb 2025AY 2016-17

Bench: Shri V. Durga Rao & Shri Khettra Mohan Roy

For Appellant: -None-For Respondent: Shri Abhay Y. Marathe, Sr. DR

Section 143(2)Section 147Section 148Section 250(6)Section 69

issue back to the file of learned CIT(A) with a direction to re-decide the matter in issue, after providing adequate opportunity of being heard to the assessee. Needless to say, it is the risk and responsibility of the assessee to plead and prove her case before the learned

Kadirur Service Co-Operative Bank Ltd, Kadirur vs. ITO, Ward-2, Kannur

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

ITA 872/COCH/2023[AY.2018-19]Status: DisposedITAT Cochin04 Feb 2025

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm Assessment Year: 2018-19 Kadirur Service Co-Op. Bank Ltd. .......... Appellant Kadirur, Thalassery, Kannur 670642 [Pan: Aacak6088R] Vs. The Income Tax Officer .......... Respondent Ward - 2, Kannur Appellant By: Shri Arun Raj, Advocate Respondent By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 23.01.2025 Date Of Pronouncement: 04.02.2025

For Appellant: Shri Arun Raj, AdvocateFor Respondent: Smt. Leena Lal, Sr. D.R

Section 143(3)Section 80P

justice the matter is set aside to the file of the AO for de novo adjudication in accordance with law after affording opportunity of being heard to the appellant. 8. In the result, appeal filed by the assessee is allowed for statistical purposes. Order pronounced in the open court

Sankirtana Movement Trust, Jaipur vs. ITO Ward 6(2), Jaipur

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

ITA 840/JPR/2024[NA]Status: DisposedITAT Jaipur04 Feb 2025

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

For Appellant: Shri R.S. Poonia, CAFor Respondent: Shri Anup Singh, Addl. CIT-DR

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

course of hearing, the ld. AR of the assessee in the above appeals mainly submitted that the assessee was not provided adequate opportunity of being heard by the ld. CIT(E) and thus the orders should be quashed being ex- parte orders and against the principles of natural justice. Further

Sankirtana Movement Trust, Jaipur vs. ITO Ward 6(2), Jaipur

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

ITA 839/JPR/2024[NA]Status: DisposedITAT Jaipur04 Feb 2025

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

For Appellant: Shri R.S. Poonia, CAFor Respondent: Shri Anup Singh, Addl. CIT-DR

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

Sankirtana Movement Trust, Jaipur vs. ITO Ward 6(2), Jaipur

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

ITA 838/JPR/2024[NA]Status: DisposedITAT Jaipur04 Feb 2025

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

For Appellant: Shri R.S. Poonia, CAFor Respondent: Shri Anup Singh, Addl. CIT-DR

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

Sankirtana Movement Trust, Jaipur vs. ITO Ward 6(2), Jaipur

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

ITA 837/JPR/2024[NA]Status: DisposedITAT Jaipur04 Feb 2025

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

For Appellant: Shri R.S. Poonia, CAFor Respondent: Shri Anup Singh, Addl. CIT-DR

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

Raja Ram Choudhary, Malpura vs. Income Tax Officer Ward Tonk, Tonk

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

ITA 1282/JPR/2024[2012-2013]Status: DisposedITAT Jaipur04 Feb 2025AY 2012-2013

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

For Appellant: Shri Saurav Harsh, AdvocateFor Respondent: Shri Gautam Singh Choudhary, JCIT-VH

Section 148oSection 250Section 68o

view that lis between the parties has to be decided on merits so that nobody’s rights could be scuttled down without providing opportunity of being heard to the assessee. Hence, the matter is restored to the file of the ld. CIT(A) to decide it afresh by providing

DCIT Central Circle 1(1) Ahmedabad, Ahmedabad vs. Pinac Stock Brokers Private Limited, Ahmedabad

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 858/AHD/2024[2011-12]Status: DisposedITAT Ahmedabad04 Feb 2025AY 2011-12

Bench: Dr.Brr Kumar & Shri T.R Senthil Kumar

For Appellant: Shri Deepak R Shah, ARFor Respondent: Shri R N Dsouza, CIT.DR

Section 271(1)(c)Section 275Section 68

proceedings for the imposition of penalty shall be passed-(a)unless the assessee has been heard, or has been given a reasonable opportunity of being heard;(b)after the expiry of six months from the end of the month in which the order of the Commissioner (Appeals) or the Appellate

Aryavysya Seva Sangham Pattana, Warangal vs. Income Tax Officer, Ward-1, Warangal

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

ITA 25/HYD/2025[2017-18]Status: HeardITAT Hyderabad04 Feb 2025AY 2017-18

Bench: Shri Laliet Kumar & Shri Manjunatha, G.आ.अपी.सं /Ita No. 25/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2017-18) Aryavysya Seva Sangham Vs. Income Tax Officer Pattana Ward 1 Warangal Warangal Pan:Aadaa1704H (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri P Vinod, Advocate राज" व "ारा/Revenue By:: Smt. Harshita Chouhan, Dr सुनवाई की तारीख/Date Of Hearing: 04/02/2025 घोषणा की तारीख/Pronouncement: 04/02/2025 आदेश/Order Per Manjunatha, G. A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 17/12/2024 Of The Learned Cit (A)-Nfac Delhi, Relating To A.Y.20176-18. 2. The Assessee Raised The Following Grounds Of Appeal: “1. On The Facts & Circumstances Of The Case, The Order Of The Ld. Cit(A) Is Erroneous Both On Facts & In Law Apart From Being Passed In Violation Of Principles Of Natural Justice. 2. The Ld. Cit(A) Erred In Sustaining The Addition Of Rs. 33,34,200/ As Unexplained Money Under Section 69A Of The Act. The Ld. Cit(A) Erred In Sustaining The Addition

For Appellant: Shri P Vinod, AdvocateFor Respondent: : Smt. Harshita Chouhan, DR

Section 139Section 142(1)Section 69A

issue of cash deposits in light of various evidences filed by the assessee before the Assessing Officer. Therefore, to give one more opportunity of being heard, we are of Page 3 of 4 ITA No 25 of 2025 Aryavysya Seva Sangham Pattana the considered view that, the issue needs ... restore the issue to the file of the learned CIT (A) to reconsider the issue afresh after providing one more opportunity of being heard to the assessee. Needless to say, the assessee shall file all the requisite details and evidences before the learned CIT (A) as and when the appeal

Ivy Comptech Private Limited, Hyderabad vs. DCIT., Circle 2(1), Hyderabad

In the result, the appeal of the assessee is allowed

ITA 908/HYD/2024[2020-21]Status: DisposedITAT Hyderabad04 Feb 2025AY 2020-21

Bench: Shri Laliet Kumar, Hon’Ble & Shri G. Manjunatha, Hon’Bleassessment Year: 2020-21 Ivy Competech Private Limited, Vs. The Deputy Commissioner Of Income Tax, Hyderabad. Circle 2(1), Hyderabad. Pan : Aaac18884K. (Appellant) (Respondent) Assessee By: Shri Nageswara Rao, Advocate. Revenue By: Ms. M. Narmada, Cit-Dr Date Of Hearing: 20.01.2025 (Hybrid Hearing) Date Of Pronouncement: 04.02.2025

For Appellant: Shri Nageswara Rao, AdvocateFor Respondent: Ms. M. Narmada, CIT-DR

Section 143(2)Section 143(3)Section 144BSection 144CSection 144C(13)Section 144C(5)Section 92C

conformity with the directions, complete, notwithstanding anything to the contrary contained insection 153 or section 153B, the assessment without providing any further opportunity of being heard to the assessee, within one month from the end of the month in which such direction is received." "Section 282: Service of notice generally ... which such direction is received. Sub- section (13) also provides that the Assessing Officer can complete the assessment without providing any further opportunity of being heard to the assessee. This means that the moment the Assessing Officer receives the directions under sub-section (5), he has to straightaway complete