“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

Deepto Roy, Mumbai vs. Dic, Circle-16(2), Mumbai

In the result the appeal filed by the assessee stands partly allowed for statistical purposes

ITA 4628/MUM/2024[2018-19]Status: DisposedITAT Mumbai17 Dec 2024AY 2018-19

Bench: Smt Beena Pillai & Smt Renu Jauhriassessment Year: 2018-19 Deepto Roy Deputy Commissioner 1103, C Wing, Of Income Tax, Circle Tower I, 16(2) Ashok Gardens, Aayakar Bhawan, T J Road, Vs. Mumbai. Sewree Mumbai, Kalachowki S.O., Mumbai- 400033. Pan: Aikpr5472P Appellant : Respondent

For Appellant: RespondentFor Respondent: Shri. R. R. Makwana, SR. D.R

Section 148Section 69Section 69C

necessary verification of the issues based on the evidences filed by the assessee in accordance with law. Needless to say that proper opportunity of being heard must be granted to the assessee. Accordingly the grounds raised by the assessee stands allowed for statistical purposes. In the result the appeal filed

ACIT Circle 8(3)(1), Mumbai vs. Ganjam Trading Co. Pvt. Ltd., Mumbai

In the result, the appeal of the Revenue is dismissed and the Cross

ITA 458/MUM/2024[2018-19]Status: DisposedITAT Mumbai17 Dec 2024AY 2018-19

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhan: A.Y. : 2018-19 C.O. No. 99/Mum/2024 : A.Y. : 2018-19 (Arising Out Of Ita No. 458/M/24)

For Appellant: Shri Madhur Agrawal, Advocate &For Respondent: Dr. Kishor Dhule, CIT-DR

Section 115JSection 14ASection 2Section 32

taking into account the decision of the Special bench in the case of Vireet Investments Ltd (supra). After affording adequate 16 C.O.No. 99/Mum/2024 opportunity of being heard to the assessee, the AO may take appropriate decision in accordance with the law. 18. In the result, the appeal of the Revenue

ACIT 2 2 1, Mumbai vs. Learningmate Solutions Private Limited, Mumbai

In the result, the appeal of the Revenue is treated as allowed for statistical purposes

ITA 3659/MUM/2024[2022-23]Status: DisposedITAT Mumbai17 Dec 2024AY 2022-23

Bench: Shri B.R. Baskaran & Shri Raj Kumar Chauhanassessment Year : 2022-23 Acit-2(2)(1), Learningmate Solutions Private 5Th Floor, Limited, Aayakar Bhavan, Vs. Level 7 To 10, M.K.Road, 74 Techno Park, Mumbai. 74/Ii, C Cross Road, Midc, Marol Industrial Area, Andheri (East) Mumbai Pan : Aaacl9067F (Appellant) (Respondent) Assessee By : Shri Dhanesh Bafna & Shri Hardik Nirmal & Ms. Tejal Saraf Revenue By : Dr. K.R. Subhash, Cit-Dr Date Of Hearing : 13-11-2024 Date Of Pronouncement : 17-12-2024

For Appellant: Shri Dhanesh Bafna &For Respondent: Dr. K.R. Subhash, CIT-DR

Section 143(1)Section 143(1)(a)Section 28

Ld.Addl./JCIT(A) and restore this issue to the file of the AO for examining the same afresh. After providing adequate opportunity of being heard to the assessee, the AO may take appropriate decision in accordance with law. 9. In the result, the appeal of the Revenue is treated

Orion India Systems Private Limited, Mumbai Maharashtra vs. PCIT, Mumbai-Six Circle Fifteen (One)(One)

In the result, the appeal by the assessee is dismissed

ITA 1449/MUM/2024[2018-19]Status: DisposedITAT Mumbai17 Dec 2024AY 2018-19

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailassessment Year 2018-19

For Appellant: Ms. Khevana GandhiFor Respondent: Mr. R.A. Dhyani, CIT-DR

Section 142(1)Section 143(2)Section 143(3)Section 144BSection 263Section 50B(1)Section 92C

transferor company has declared profits on the transfer and paid taxes on the same and accordingly re-assess the income after giving an opportunity of being heard to the assessee. Being aggrieved, the assessee is in appeal before us. 9. During the hearing, the learned Authorized Representative (“learned

Sukhdev Singh, Kurukshetra vs. ITO, Ward -1, Kurukshetra

ITA 402/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh16 Dec 2024AY 2012-13

Bench: This Tribunal. The Assessee Is Aggrieved By The Order Bearing

For Appellant: NoneFor Respondent: Dr. Ranjit Kaur, Addl.CIT Sr.DR

Section 144Section 144BSection 243ASection 250Section 253

402/CHD/2024 A.Y. 2012-13 3 “1. That on the facts and circumstances of the case, and on the principal of natural justice, an opportunity of being heard was denied to the appellant as all the hearing notices by the CIT(A) were sent on wrong address. 2. The appellant craves

A.B. Sugars Limited, Punjab vs. Principal Commissioner of Income Tax-1, Chandigarh

In the result, the appeal of the assessee is allowed

ITA 300/CHANDI/2024[2017-2018]Status: DisposedITAT Chandigarh16 Dec 2024AY 2017-2018

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri T.N. Singla, C.AFor Respondent: Shri Rohit Sharma, CIT DR

Section 143(3)Section 263Section 80ISection 92C

facts and law. 2. That the order passed by the Learned PCIT is without Jurisdiction. 3. That the learned PCIT has not provided opportunity of being heard asked in the written submission submitted by the appellant in the interest of natural justice. 4. That the appellant gave all the required ... Assessing Officer a; the time of the assessment proceedings in consequence to this order. The Assessing Officer shall allow the assessee adequate opportunity of being heard and to make relevant submissions. It may be ensured that the fresh assessment order is passed within the prescribed time as stipulated under section

A.B. Sugars Limited, Punjab vs. Principal Commissioner of Income Tax -1, Chandigarh

In the result, the appeal of the assessee is allowed

ITA 299/CHANDI/2024[2018-2019]Status: DisposedITAT Chandigarh16 Dec 2024AY 2018-2019

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri T.N. Singla, C.AFor Respondent: Shri Rohit Sharma, CIT DR

Section 143(3)Section 263Section 80ISection 92C

Jagroop Singh, Barnala vs. ITO, W-1, Barnala

In the result, the appeal filed by the appellant is treated as dismissed

ITA 217/CHANDI/2024[2012-13]Status: DisposedITAT Chandigarh16 Dec 2024AY 2012-13

Bench: This Tribunal. The Assessee Is Aggrieved By The Order Bearing No. Itba/Nfac/S/250/2023-24/105946628(1) Dt. 08/01/2024 Passed By The Cit(A) Under Section 250(6) Of The Act Which Is Hereinafter Referred To As The “Impugned Order”. The Relevant A.Y. Is 2012-13 & The Corresponding Previous Year Period Is From 01/04/2011 To 31/03/2012. 2. Factual Matrix

For Appellant: Shri Pardeep Goyal, CAFor Respondent: Shri Vivek Vardhan, JCIT

Section 133(6)Section 142(1)Section 144Section 147Section 148Section 151Section 246Section 250(6)Section 253Section 271

facts and under the circumstances of the case the CIT (Appeals), NFAC has erred in law by not affording an opportunity of being heard to assessee and by not following the principles of natural justice. 2. On facts and under the circumstances of the case the CIT (Appeals), NFAC ... impugned order is illegal, not proper and is bad in law as the Ld. CIT(A) has failed to give assessee an opportunity of being heard which is in gross violation of the 5 principles of natural justice. He contended that impugned order should be set aside and matter

Lotus Multy Speciality Hospital, Pune vs. ITO Ward 14(5) Pune, Pune

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

ITA 2258/PUN/2024[2018-19]Status: DisposedITAT Pune16 Dec 2024AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2257 & 2258/Pun/2024 िनधा"रण वष" / Assessment Years: 2016-17 & 2018-19 Lotus Multy Specialty Hospital, V The Income Tax Officer, Shewalewadi Phata, Pune S Ward-14(5), Pune. Solapur Road, Manjari, Pune – 412307. Pan: Aaffl6270J Appellant/ Assessee Respondent / Revenue Assessee By Shri Girish Ladda – Ca/Ar Revenue By Smt Shraddha Nichal - Addl.Cit(Dr) Date Of Hearing 12/12/2024 Date Of Pronouncement 16/12/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: These Two Appeals Filed By The Assessee Against The Separate Orders Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] For Assessment Year 2016-17 & 2018-19; Dated 15.02.2024 & 04.07.2024 Respectively, Passed U/Sec.250 Of The Income Tax Act, 1961. Since The Issue Involved Is Common, Both These Appeals Were Heard Together & Decided By The Common Order. We Will Take The A.Y.2016-17 As A Lead Case.

Section 246ASection 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)

without discussing each and every ground and merits of the case and merely dismissed for non-compliance. Hence, ld.AR requested for one more opportunity of being heard to the assessee. Submission of ld.Departmental Representative(ld.DR) : 3. The ld.DR for the Revenue relied on the order of Assessing Officer

Lotus Multy Speciality Hospital, Pune vs. ITO Ward 14(5) Pune, Pune

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

ITA 2257/PUN/2024[2016-17]Status: DisposedITAT Pune16 Dec 2024AY 2016-17

Section 246ASection 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)

Shri Venkatesh Nisarg Sahakari Gruhrachna Sanstha Maryadit, Pune vs. ACIT Ward 9(1), Pune

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

ITA 2174/PUN/2024[2018-19]Status: DisposedITAT Pune16 Dec 2024AY 2018-19

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.2174/Pun/2024 िनधा"रण वष" / Assessment Year: 2018-19 Shri Venkatesh Nisarg Sahakari V The Acit, Gruhrachna Sanstha Maryadit, S Ward-9(1), Pune. S.No.56/3/1, Vadagaon Bk, Near Hotel Ashirvad, Haveli, Pune – 411041. Pan: Aaras2349J Appellant/ Assessee Respondent / Revenue Assessee By Shri B.C.Malakar – Ar Revenue By Smt Shraddha Nichal – Addl.Cit(Dr) Date Of Hearing 12/12/2024 Date Of Pronouncement 16/12/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] For Assessment Year 2018-19 Dated 30.08.2024 Passed U/Sec.250 Of The Income Tax Act, 1961. The Assessee Has Raised The Following Grounds Of Appeal : “1. On The Facts & In The Circumstances Of The Case & In Law The Ld. Cit(A), Addl/Jcit(A)-2, Bangaluru Erred In Dismissing The Appeal Of The Appellant Assessee Society Thereby Confirming The Computation Of Total Income Made In The Intimation U/S. 143(1) Of The I.T. Act, 1961 Dated 12/07/2019 Issued By The Dcit, Cpc Bangaluru Assessing The Total Income In The Case Of The Appellant At Rs.10,04,160/- Ignoring & Without Appreciating The Facts Of The Case Appellant Housing Society That The Appellant Is A Mutual Society Created By The Members & The Source Of Its Income Was From The Members Only & Therefore Its Income Was Qualified For Exemption Under The Act On Concept Of Mutuality As A Mutual Concern. The Appellate Order Passed By The Appellate Authority Be Quashed & The Assessing Officer Be Directed To Re-Compute The Total Income Of The Appellant At Rs. Nil Treating The Appellant As A Mutual Society.

Section 143(1)Section 250Section 80PSection 80P(2)(a)

without discussing each and every ground and merits of the case and merely dismissed for non-compliance. Hence, ld.AR requested for one more opportunity of being heard to the assessee. 3 Submission of ld.Departmental Representative(ld.DR) : 3. The ld.DR for the Revenue relied on the order of Assessing Officer

Sbpl Infrastructure Limited, Hyderabad vs. DCIT., Circle-3(1), Hyderabad

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

ITA 685/HYD/2024[2014-15]Status: DisposedITAT Hyderabad16 Dec 2024AY 2014-15

Bench: Shri Vijay Pal Rao & Shri Manjunatha G.आ.अपी.सं /Ita No.685/Hyd/2024 (निर्धारण वर्ा/Assessment Year: 2014-15) Sbpl Infrastructure Vs. Deputy Commissioner Limited Of Income Tax Hyderabad Circle-3(1) [Pan : Aaccs9014M] Hyderabad (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri Sashank Dundu, Ar रधजस् व द्वधरध/Revenue By: Shri M.Vijay Kumar,Cit-Dr सुिवधई की तधरीख/Date Of Hearing: 04/12/2024 घोर्णध की तधरीख/Date Of 16/12/2024 Pronouncement: आदेश / Order Per. Manjunatha G., A.M: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals) [Learned Cit(A)], National Faceless Appeal Centre (Nfac), Delhi Dated 13.02.2024 & Pertains To A.Y.2014-15. 2. This Appeal Filed By The Assessee Is Time Barred By 94 Days. The Assessee Filed A Petition For Condonation Of Delay & Submitted That Shri Manoj Sharma, Chief Financial Officer Of The Appellant Company, Who Was Entrusted With The Job Of Looking

For Appellant: Shri Sashank Dundu, ARFor Respondent: Shri M.Vijay Kumar,CIT-DR

Section 14A

claim of the Appellant with respect to the profit being ₹3,87,28,089/- instead of ₹5,53,81,904/- without providing an opportunity of being heard and without giving any explanation in the final Assessment Order w.r.t. why the profit declared by the 3 appellant was being rejected/not considered ... computing Assessed Income instead of the profit excluding extraordinary items as available in the P&L account thereby not providing a fair opportunity of being heard and violating the principles of Natural Justice. 6. The NFAC erred in confirming the disallowance made by the AO u/s 14A of the Income

Sankar Saha, Kolkata vs. ITO, Ward-43(1), Kol, Kolkata

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

ITA 943/KOL/2024[2020-2021]Status: DisposedITAT Kolkata16 Dec 2024AY 2020-2021

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Manish Tiwari, ARFor Respondent: Shri Jitendra Kantilal Surti, DR

Section 144Section 270ASection 56(2)(X)

Accordingly, we restore the issue back to the file of the ld. AO with a direction to decide the same denovo after reasonable opportunity of being heard to the assessee. 943/KOL/2024 04. The assessee has challenged the appellate order confirming the imposition of penalty of ₹3,37,742/- u/s 270A

Sankar Saha, Kolkata vs. ITO, Ward - 43(1), Kol, Kolkata

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

ITA 942/KOL/2024[2020-2021]Status: DisposedITAT Kolkata16 Dec 2024AY 2020-2021

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Manish Tiwari, ARFor Respondent: Shri Jitendra Kantilal Surti, DR

Section 144Section 270ASection 56(2)(X)

Rajiv Ohri, Gurgaon, Haryana vs. A.C.I.T., Circle - 62, Kolkata

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

ITA 1924/KOL/2024[2014-2015]Status: DisposedITAT Kolkata16 Dec 2024AY 2014-2015

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Rajiv Ohri Acit, Circle-62, Kolkata 1508 A, The Magnolias, Dlf Golf Bamboo Villa, 169, A.J.C. Bose Links, Dlf Phase V, Golf Course Road, Kolkata, West Bengal, Vs. Road, Galleria Dlf-Iv, Gurgaon, Kolkata-700017 Haryana-122009 (Appellant) (Respondent) Pan No. Aafp07001A Assessee By : Shri Siddarth Agarwal, Ar Revenue By : Shri Subhendu Datta, Dr Date Of Hearing: 03.12.2024 Date Of Pronouncement : 16.12.2024

For Appellant: Shri Siddarth Agarwal, ARFor Respondent: Shri Subhendu Datta, DR

Section 69A

decide the issue denovo after taking into account all the necessary documents/ evidences, and after Rajiv Ohri; A.Y. 2014-15 allowing a reasonable opportunity of being heard to the assessee. The appeal of the assessee is allowed for statistical purposes. 06. In the result, the appeal of the assessee

Intelligent Infrastructure Ltd., Kolkata vs. D.C.I.T., Circle - 7(1), Kolkata

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

ITA 1907/KOL/2024[2012-2013]Status: DisposedITAT Kolkata16 Dec 2024AY 2012-2013

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Dcit Intelligent Infrastructure Ltd. Aaykar Bhavan, P-7, 3/1, Dr. U.N. Brahmachari Street, Chowringhee Suare, Vs. Kolkata-700017, West Bengal Kolkata-700069, West Bengal (Appellant) (Respondent) Pan No. Aabcp8597P Assessee By : Shri N.S. Saini, Ar Revenue By : Shri Vineet Kumar, Dr Date Of Hearing: 11.12.2024 Date Of Pronouncement : 16.12.2024

For Appellant: Shri N.S. Saini, ARFor Respondent: Shri Vineet Kumar, DR

file of Intelligent Infrastructure Ltd; A.Y. 2012-13 the ld. CIT (A) with a direction to decide the same after affording reasonable opportunity of being heard to the assessee. 06. In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced in the open court

Aar Commercial Company Limited [Since Merged With Gallant Ispat Limited (Formerly Known As Gallantt Metal Limited)], Gorakhpur, Uttar Pradesh vs. D.C.I.T., Circle - 3(1), Kolkata

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

ITA 1573/KOL/2024[2015-2016]Status: DisposedITAT Kolkata16 Dec 2024AY 2015-2016

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm Aar Commercial Company Limited Dcit, Circle 3(1) (Since Merged With Gallant Aaykar Bhavan, P-7, Ispat Limited)(Formerly Known Chowringhee Square, As Gallantt Metal Limited) Vs. Kolkata-700069, Al-5, Gida Sahjanwa, West Bengal Gorakhpur-273209, Uttar Pradesh (Appellant) (Respondent) Pan No. Aacca2642K Assessee By : Shri Miraj D. Shah, Ar Revenue By : Shri Vineet Kumar, Dr Date Of Hearing: 11.12.2024 Date Of Pronouncement : 16.12.2024

For Appellant: Shri Miraj D. Shah, ARFor Respondent: Shri Vineet Kumar, DR

appeal to the file of the ld. CIT (A) with a direction to decide the same denovo on merit after affording a reasonable opportunity of being heard to the assessee. 05. In the result, the appeal of the assessee is allowed for statistical purposes. Order pronounced in the open court

M/S. Akshaya Builders Developers Promoters, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-3(2)(1), Bengaluru

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

ITA 1737/BANG/2024[2018-19]Status: DisposedITAT Bangalore16 Dec 2024AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Sri V. Narendra Sharma, A.RFor Respondent: Sri Subramanian S., D.R

Section 142(1)

before us and contended that the order of ld. CIT(A) is not tenable as the same has been passed without affording reasonable opportunity of being heard. However, the ld. Counsel for the assessee accepted that notice issued from the office ld. CIT(A) was duly served upon the assessee

M/S. Akshaya Builders Developers Promoters, Bengaluru vs. Assistant Commissioner of Income Tax, Circle-3(2)(1), Bengaluru

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

ITA 1736/BANG/2024[2017-18]Status: DisposedITAT Bangalore16 Dec 2024AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Sri V. Narendra Sharma, A.RFor Respondent: Sri Subramanian S., D.R

Section 142(1)

Bosch Automotive Electronics India Private Limited, Karnataka vs. Assessment Unit, Income-Tax Department and DCIT, Circle 2(1)(1), Bangalore

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

ITA 1473/BANG/2024[Assessment Year 2020-21]Status: FixedITAT Bangalore16 Dec 2024

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Sri Suryanarayana, A.RFor Respondent: Sri N. Senthil, D.R

Section 130Section 139Section 143(1)Section 143(2)Section 144C(1)Section 40Section 92C

issue also we remit the matter to the file of ld AO for examining afresh in accordance with law, who after providing reasonable opportunity of being heard to the assessee. These observations will take care of the grounds of assessee running from ground Nos.10 to 14. 5.3 In ground No.15