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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

Panache Salon and Academy Pvt Ltd, Mumbai vs. ACIT-(Central Circle )-4(3), Mumbai

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

ITA 5347/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Dec 2024AY 2017-18

Bench: Hon’Ble Shri Sandeep Gosainvs. Acit, Circle – 4(3) Panache Salon & 1921, 19Th Floor, Academy Pvt Ltd Air India Bldg, 1St Floor, Kesarinath Nariman Point, Apartment Chs Ltd, Mumbai. S.V Road, Goregoan (W) Mumbai. Pan/Gir No. Aabcw3591Q (Applicant) (Respondent)

Section 250

assessment year 2017-18. 2. The Ld. AR while referring to the grounds of appeal submitted that he was not granted proper opportunity of being heard by Ld. CIT(A), thereby violating the principles of 2 Panache Salon and Academy Pvt Ltd, Mumbai natural justice. In this regard I have

Konica Minolta Marketing Services India Private Limited, Malad (W), Mumbai vs. ACIT, Circle 12(2)(1), Mumbai

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

ITA 5043/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Dec 2024AY 2017-18

Bench: Shri Sandeep Singh Karhail & Smt. Renu Jauhri

For Appellant: Ms. Bharati MalasurFor Respondent: Shri Kiran Unavekar
Section 144Section 250

made by Ld. AO by passing order u/s 144 of the Act by passing an exparte order without giving the appellant an adequate opportunity of being heard. 3. That an adequate opportunity must be granted to the appellant and the matter may kindly be sent back ... facts in assessing the income of the assessee by an order passed u/s 144 of the Act without giving the assessee an adequate opportunity of being heard and without contacting the assessee regarding non-compliance of notices, if any, during the assessment proceedings. 5. That the Ld. CIT (A) erred

Sau Anandibai Hirachand Shah Phaltankar Trust, Pune vs. Commissioner of Income Tax (Exemption), Pune

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

ITA 60/PUN/2024[-]Status: DisposedITAT Pune23 Dec 2024

Bench: DR.DIPAK P. RIPOTE (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

Section 12A

erred both in facts and in law in cancelling the provisional registration u/s 12AB under Income Tax Act, 1961 without providing any opportunity of being heard for the same. 3. The learned CIT Exemption has erred both in facts and in law in rejecting the application for registration

Kai Sau Alkatai Palodkar Khajagi Shikshak Sevakanchi Sahakari Patsanstha M, Sillod vs. Income Tax Office Ward 1(1) Auranbgad, Auranabad

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

ITA 2372/PUN/2024[202223]Status: DisposedITAT Pune23 Dec 2024

Bench: Dr.Manish Borad

For Appellant: Shri Suraj KumarFor Respondent: Shri Sourabh Nayak
Section 139(4)Section 154Section 250Section 80ASection 80P

outcome of the applications filed by the assessee for condonation of delay on 19.11.2024 to ld. PCCIT, after providing the assessee with necessary opportunity of being heard. 10. In the result, all the appeals of the assessee are allowed for statistical purposes. Order pronounced on this 23rd day of December

Kai Sau Alkatai Palodkar Khajagi Shikshak Sevakanchi Sahakari Patsanstha M, Sillod vs. Income Tax Officer Ward 1(1) Aurangabad, Aurangabad

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

ITA 2371/PUN/2024[2021-22]Status: DisposedITAT Pune23 Dec 2024AY 2021-22

Bench: Dr.Manish Borad

For Appellant: Shri Suraj KumarFor Respondent: Shri Sourabh Nayak
Section 139(4)Section 154Section 250Section 80ASection 80P

outcome of the applications filed by the assessee for condonation of delay on 19.11.2024 to ld. PCCIT, after providing the assessee with necessary opportunity of being heard. 10. In the result, all the appeals of the assessee are allowed for statistical purposes. Order pronounced on this 23rd day of December

Kai Sau Alkatai Palodkar Khajagi Shikshak Sevakanchi Sahakari Patsanstha M, Sillod vs. Income Tax Officer Ward 1(1), Aurangabad

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

ITA 2370/PUN/2024[2019-20]Status: DisposedITAT Pune23 Dec 2024AY 2019-20

Bench: Dr.Manish Borad

For Appellant: Shri Suraj KumarFor Respondent: Shri Sourabh Nayak
Section 139(4)Section 154Section 250Section 80ASection 80P

outcome of the applications filed by the assessee for condonation of delay on 19.11.2024 to ld. PCCIT, after providing the assessee with necessary opportunity of being heard. 10. In the result, all the appeals of the assessee are allowed for statistical purposes. Order pronounced on this 23rd day of December

Suman Gandhi, Kolkata vs. I.T.O., Ward - 36(2), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 1759/KOL/2024[2016-2017]Status: DisposedITAT Kolkata23 Dec 2024AY 2016-2017

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1759/Kol/2024 Assessment Year: 2016-17 Suman Gandhi…………………………....……………………....Appellant E-24/7, Karunamoyee, Sech Bhawan, Salt Lake, Kolkata – 700091. [Pan: Axcpg3145R] Vs. Ito, Ward-36(2), Kolkata…..….…….…............................…..…..... Respondent Appearances By: Shri Anil Kochar, Ar, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborthy, Addl. Cit & Somnath Das Biswas, Sr. Drs, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2024 Date Of Pronouncing The Order : December 23, 2024 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 25.06.2024 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. Brief Facts Of The Case Are That The Assessing Officer Initiated Proceedings U/S 147 Of The Act For The Assessment Year 2016-17 Based On The Information Received From Adit(Inv.), Unit-5, Kolkata, Wherein, It Was Observed That The Assessee Had Claimed Income From Investment Of Shares & Loans For Earning Interest, Insurance Commission & Tuition Fees. The Assessing Officer During The Assessment Proceedings Noticed That The Assessee Sold 20,000 & 29,720 Number Of Shares Of Grapco Mining Ltd. & Patheja Forgings Ltd. Respectively Had Been Sold In Physical Form During The Year For Rs.2,00,000/- & Rs.2,97,200/-

Section 147Section 250

direct the ld. CIT(A) to decide the issue on the merits of the case after providing due opportunity of being heard to the assessee. We also direct the assessee to comply with the notices issued by the ld. CIT(A). 7. In terms of the above, the appeal

Nemai Charan Pandit, Kadamtala vs. Circle 46, Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 1343/KOL/2024[2017-18]Status: DisposedITAT Kolkata23 Dec 2024AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No. 1343/Kol/2024 Assessment Year: 2017-2018 Nemai Charan Pandit,……………………………Appellant 116/2, Makardah Road, Kadamtala, Howrah-711101, West Bengal [Pan:Afvpp5703K] -Vs.- Circle-46, Kolkata,………………………….……Respondent 3, Government Place West, Kolkata-700001 Appearances By: Shri Pranabesh Sarkar, Advocate, Appeared On Behalf Of The Assessee Shri S.B, Chakraborthy, Addl. Cit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: December 19, 2024 Date Of Pronouncing The Order: December 23, 2024 O R D E R

Section 144Section 147Section 69A

back the whole issue to the file of ld. Assessing Officer with a direction to re-examine the issues afresh after affording reasonable opportunity of being heard to the assessee. The assessee is also directed to cooperate with the ld. Assessing Officer and file all the evidences, which are available

Balhanuman Commodities Private Limited, Kolkata vs. CIT(A), NFAC

The appeal of the assessee is allowed for statistical purposes

ITA 1129/KOL/2024[2012-13]Status: DisposedITAT Kolkata23 Dec 2024AY 2012-13

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1129/Kol/2024 Assessment Year: 2012-13 Balhanuman Commodities Pvt. Ltd..……………………....Appellant 309, B. B. Ganguly Street, W.B – 700012. [Pan: Aadcb6195K] Vs. Cit(A), Nfac………………..….…….…............................…..…..... Respondent Appearances By: Shri Manish Tiwari, Advocate, Appeared On Behalf Of The Appellant. Shri Somnath Das Biswas, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 17, 2024 Date Of Pronouncing The Order : December 23, 2024 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 22.03.2024 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. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Relevant Assessment Year By Declaring An Income Of Rs.5590/-. The Case Of The Assessee Was Selected For Scrutiny Assessment. The Case Of The Assessee Was Assessed U/S 144 Of The Act & Statutory Notices Were Issued To The Assessee. But The Notices Could Not Be Served On The Assessee As The Business Of The Assessee Had Been Closed & There Was No Response To The Notices Issued. Due To The Non- Compliance, The Assessing Officer Compelled To Frame The Assessment Order U/S 144 Of The Act. On The Basis Of Material Available On Record, The Assessing Officer Added A Sum Of Rs.30,50,000/- Representing

Section 144Section 250Section 250(6)

issue to the file of the ld. CIT(A) with a direction to re-examine the case on merits after giving reasonable opportunity of being heard to the assessee to represent its case. We also direct the assessee to diligently comply with the notices issued and participate sincerely

United India Insurance Co. Limited, Royapettah, Chennai vs. DCIT Corprate Cricle 3(1), Chennai

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

ITA 2398/CHNY/2024[2013-14]Status: DisposedITAT Chennai23 Dec 2024AY 2013-14

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.2398 /Chny/2024 निर्धारण वर्ष /Assessment Years: 2013-14 United India Insurance Company Limited, The Deputy Manager, Cfac Department, Head Office, United India Insurance Company Limited, Floor No.9, 24, Whites Road, Peters Colony, Royapettah, Chennai-600 014 [Pan: Aaacu5552C] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By प्रत्यर्थी की ओर से /Revenue By सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख /Date Of Pronouncement Deputy Commissioner Of Income Tax, Corporate Circle-3(1), Chennai. (प्रत्यर्थी/Respondent) : Ms.Pavitra Mani, Advocate : Ms.Sheila Parthasarthy, Addl.Cit : 04.12.2024 : 23.12.2024 आदेश / Order Per Amitabh Shukla, A.M : This Appeal Is Filed Against The Order Bearing Din & Order No.Itba/Apl/S/250/2024-25/1066747754(1) Dated 16.07.2024 Of The Learned Commissioner Of Income Tax [Herein After “Cit(A), For The

Section 201Section 250

order to meet the ends of natural justice, we are of the considered opinion that the assessee shall be afforded one more opportunity of being heard to furnish the details. Accordingly, we set aside the order of the Id. CIT(A) and remit the matter back ... adjudicate the matter de novo after giving one more opportunity of being heard to the assessee. The assessee is also directed to furnish complete details with evidence before the Ld. First Appellate Authority without fail. :- 3 -: ITA No.2398/Chny/2024 5.0. In the result, the appeal of the assessee is allowed

Krishnaveni, Madurai vs. ITO, Ncw-2(3), Madurai

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

ITA 2318/CHNY/2024[2018-19]Status: DisposedITAT Chennai23 Dec 2024AY 2018-19

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.2318 /Chny/2024 निर्ाारण वर्ा /Assessment Years: 2018-19 M/S.Krishnaveni The Income Tax Officer, No.18B, South Street, Non-Corpn Ward-2(3) Singarayar Colony, Madurai Bibikulam, Madurai-625002. [Pan: Clfpk4336P] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Ms.L.Sweety, Advocate प्रत्यर्थी की ओर से /Revenue By : Shri K.N.Dhandapani, Cit सुिवाई की तारीख/Date Of Hearing : 27.11.2024 घोर्णा की तारीख /Date Of Pronouncement : 23.12.2024 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Ms.L.Sweety, AdvocateFor Respondent: Shri K.N.Dhandapani, CIT
Section 250

passed by NFAC, Delhi. :- 2 -: 2.0 At the outset the Ld. Counsel of the assessee submitted that it has not been given adequate opportunity of being heard in as much as the details filed by it before the Ld. AO and the Ld. CIT(A) have not been considered before ... placed upon the decision of Hon’ble Apex Court in the case of TIN box 249 ITR 216. The Ld. AO shall give opportunities of being heard to the assesse and it shall be bounden upon the assesse to comply with the notices issued

Jain Investment Advisors Pvt Ltd, Mumbai vs. ITO, Ward 10(2)(1), Mumbai

Appeal is allowed for statistical purposes

ITA 5823/MUM/2024[2020-21]Status: DisposedITAT Mumbai23 Dec 2024AY 2020-21

Bench: CIT(A) and all this

For Appellant: Shri Tanzil PadvekarFor Respondent: Shri Ajay Singh
Section 143(3)Section 144BSection 250

Assessee was not able to place the aforesaid documents/explanation for consideration before CIT(A), as the appeal was dismissed without granting the Assessee opportunity of being heard. 6. Per contra, the learned Departmental Representative relied upon the order passed by the CIT(A) and submitted that the Assessee ... directed to decide the aforesaid application seeking condonation of delay in filing appeal as per law after granting the Assessee a reasonable opportunity of being heard, and thereafter, adjudicate the grounds raised by the Assessee in appeal before CIT(A), in case the delay in filing the appeal is condoned

Vivek Ramrao Paraskar, Mumbai vs. Assistant Commissioner 32(2), Mumbai

Appeal is allowed for statistical purposes

ITA 5821/MUM/2024[2017-2018]Status: DisposedITAT Mumbai23 Dec 2024AY 2017-2018

Bench: SHRI RAHUL CHAUDHARY, JUDICIAL MEMBER SHRI OMKARESHWAR CHIDARA (Accountant Member)

For Appellant: NoneFor Respondent: Shri Ajay Singh
Section 143(3)

order u/s.143(3) of the Income Tax Act, 1961 for AY 2011-2012. 4. Order passed by Hon’ble A.O. was without giving opportunity to be heard which is bad in law.” 3. The relevant facts in brief are the appeal preferred by the Assessee against the Assessment Order dated ... that since the Assessee did not participate the in appellate proceedings, the CIT(A) had no option but to dismiss the appeal. Sufficient opportunity of being heard was granted to the Assessee. However, the Assessee failed to avail the same. Therefore, the CIT(A) was justified in dismissing the appeal

DCIT CC 1(1), Mumbai vs. Edelweiss Tokio Life Insurance Company Ltd, Kurla, Mumbai

In the result, the appeal is allowed for statistical purposes

ITA 3802/MUM/2024[2018-19]Status: DisposedITAT Mumbai23 Dec 2024AY 2018-19

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Ajay Singh and Shri A. Pawar ARsFor Respondent: Shri Hemanshu Joshi (Sr. DR)
Section 143(3)

issue since the beginning of the assessment proceedings and yet it failed to submit the requisite documents when it was afforded opportunities of being heard during the assessment proceedings?” 3. Brief facts of the case are that during the year under consideration, it was noticed by the ld.AO that ... deemed fit. He shall give proper and adequate P a g e | 14 A.Y. 2018-19 Edelweiss Tokio Life Insurance Company Ltd. opportunity of being heard to the assessee in accordance with principles of natural justice in the set aside remand proceedings for de novo adjudication of the assessee filed

Muljibhai Patel Society for Research in Nephro Urology, Nadiad vs. The CIT(Exemption), Ahmedabad

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

ITA 1768/AHD/2024[NA]Status: DisposedITAT Ahmedabad20 Dec 2024

Bench: Shri TR Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

For Appellant: Shri Dhrunal Bhatt &For Respondent: Shri A.P. Singh, CIT-D.R
Section 80G(5)Section 80G(5)(iii)

that the matter may be set aside to the ld. CIT(E) with a direction to re- examine the matter after allowing an opportunity of being heard to the assessee. 4. Per contra, Shri A.P. Singh, the ld. CIT-D.R. had no objection in setting aside the matter back

Inklings Education Foundation, Ahmedabad vs. The CIT(Exemption), Ahmedabad

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

ITA 1335/AHD/2024[NA]Status: DisposedITAT Ahmedabad20 Dec 2024

Bench: Shri TR Senthil Kumar (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)

For Appellant: Shri D.K. Parekh, A.RFor Respondent: Shri A.P. Singh, CIT-D.R
Section 12ASection 12A(1)(ac)Section 8

sufficient and reasonable cause in not being able to respond to the notice dated 06.12.2023 regarding object No: 78 and hence adequate opportunity of being heard on the facts were not afforded. All the objects pursued being charitable, registration be directed to be granted as claimed. 5. The order passed ... justice, we deem it proper to set aside the matter to the file of the CIT(E) with a direction to allow another opportunity of being heard to the assessee and thereafter pass order in accordance with law. The Ld. CIT(E) will proceed in the matter after verifying that

Garware Technical Fibres Foundation, Pune vs. The Commissioner of Income Tax (Exemption), Pune

In the result, the appeal filed by the assessee in ITA

ITA 1944/PUN/2024[-]Status: DisposedITAT Pune20 Dec 2024

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Amol Khairnar
Section 12ASection 12A(1)(ac)Section 80G

registration u/s 12A of ITA, 1961. 3. The learned CIT (Exemption), Pune; erred in law and on facts in not providing sufficient reasonable opportunity of being heard to the appellant, as provided u/s 12AB of the ITA, 1961; to submit the details / information. Appellant contends that, Appellant is keen

Garware Technical Fibres Foundation, Pune vs. The Commissioner of Income Tax (Exemption), Pune

In the result, the appeal filed by the assessee in ITA

ITA 1943/PUN/2024[-]Status: DisposedITAT Pune20 Dec 2024

Bench: SHRI R. K. PANDA (Vice President), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: Shri Kishor B. PhadkeFor Respondent: Shri Amol Khairnar
Section 12ASection 12A(1)(ac)Section 80G

registration u/s 12A of ITA, 1961. 3. The learned CIT (Exemption), Pune; erred in law and on facts in not providing sufficient reasonable opportunity of being heard to the appellant, as provided u/s 12AB of the ITA, 1961; to submit the details / information. Appellant contends that, Appellant is keen

Girish Satyanaryan Singh, Nagpur vs. Income Tax Officer Ward-2(2), Nagpur

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

ITA 72/NAG/2024[2017-18]Status: DisposedITAT Nagpur20 Dec 2024AY 2017-18

Bench: Shri V. Durga Rao

For Appellant: Shri Rachit ThakarFor Respondent: Shri Abhay Y. Marathe
Section 143(1)(a)

filing the appeal before the learned CIT(A) by adducing proper evidence. Needless to say that the learned CIT(A) shall provide reasonable opportunity of being heard to the assessee before adjudication of issues on merit and pass order in accordance with law. 6. In the result, appeal filed

Mulchand Jaganath Ragit, Nagpur vs. ITO Ward 3(4), Nagpur

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

ITA 433/NAG/2024[2016-17]Status: HeardITAT Nagpur20 Dec 2024AY 2016-17

Bench: Shri V. Durga Rao

For Appellant: Shri Abhay AgrawalFor Respondent: Shri Abhay Y. Marathe
Section 148Section 45

learned CIT(A) and direct him to adjudicate the matter afresh on merit and in accordance with law after providing reasonable opportunity of being heard to the assessee. It is also directed that the assessee should not seek adjournment without there being a 3 Mulchand Jaganath Ragit justified reason. Accordingly