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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

Andhra Pradesh Industrial Infrastructure Corporation Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

The appeals of the assessee are allowed for statistical purposes

ITA 681/HYD/2024[2017-18]Status: DisposedITAT Hyderabad04 Dec 2024AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri B. Satyanarayana MurthyFor Respondent: : Shri Kumar Pranav, CIT-DR
Section 143(3)Section 14A

exclude the investment which has not generated exempt income for the purpose of calculation of disallowance u/s.14A of the Act after providing an opportunity of being heard to the assessee. Accordingly, ground no.6 of the assessee is allowed for statistical purposes. ITA No.681/Hyd/2024 for A.Y. 2017-18 13. The assessee

Andhra Pradesh Industrial Infrastructure Corporation Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

The appeals of the assessee are allowed for statistical purposes

ITA 680/HYD/2024[2012-13]Status: DisposedITAT Hyderabad04 Dec 2024AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri B. Satyanarayana MurthyFor Respondent: : Shri Kumar Pranav, CIT-DR
Section 143(3)Section 14A

exclude the investment which has not generated exempt income for the purpose of calculation of disallowance u/s.14A of the Act after providing an opportunity of being heard to the assessee. Accordingly, ground no.6 of the assessee is allowed for statistical purposes. ITA No.681/Hyd/2024 for A.Y. 2017-18 13. The assessee

Cube Infrastructure Private Limited, Kolkata vs. ITO Ward-9(3), Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 746/KOL/2024[2011-12]Status: DisposedITAT Kolkata04 Dec 2024AY 2011-12

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.746/Kol/2024 Assessment Year: 2011-12 Cube Infrastructure Pvt. Ltd. ……..……………………....Appellant 425, Dum Dum Park, Kolkata, W.B. – 700055. [Pan: Aadcc3318D] Vs. Ito, Ward-9(3), Kolkata…. ….…….…............................…..…..... Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Rajat Datta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 03, 2024 Date Of Pronouncing The Order : December 04, 2024 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 09.02.2024 Of The Commissioner Of Income Tax, Appeal Addl/Jcit(A)-9, Mumbai [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. At The Time Of Hearing, No One Appeared On Behalf Of The Assessee, Although Notices Were Served On Time To Time From The Registry To The Assessee Through Post On 22.08.24, 3.12.2024. As All Options Have Gone In Vain Since No One Appeared On Behalf Of The Assessee On The Consecutive Dates, Under Such Situation, We Cannot Keep This Appeal Pending For Inordinate Delay For Adjudication. We, Therefore, Feel It Necessary To Decide This Appeal On The Basis Of Material Available On Record & With The Assistance Of The Ld. Dr.

Section 249(3)Section 250

back the matter to the file of the ld. CIT(A) with a direction to re-examine the issue afresh after affording reasonable opportunity of being heard to the assessee. 4. We, after hearing the submission of the ld. DR and perusing the materials available on record, find that

Bhairablana Samabay Krishi Unnayan Samity Limited, Vill- Hatbele, Post- Hatbele vs. Assessing Officer, Assessment Unit, Income Tax Department, National Faceless Assessment Centre, Delhi

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

ITA 61/KOL/2024[2018-19]Status: DisposedITAT Kolkata04 Dec 2024AY 2018-19

Bench: Shri Sanjay Garg & Shri Rakesh Mishraassessment Year: 2018-19

For Appellant: NoneFor Respondent: Abhishek Kumar, JCIT, Sr. DR
Section 144BSection 147Section 148Section 250Section 69A

aside and the assessment is made de novo considering the return filed on the new PAN AACAB7492G and after granting an opportunity of being heard to the assessee. The assessee shall produce all necessary evidence in support the claim that the addition was not warranted in the first place. Hence

Manas, Kolkata vs. I.T.O., Ward - 1(4), Kolkata

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

ITA 1357/KOL/2024[2022-2023]Status: DisposedITAT Kolkata04 Dec 2024AY 2022-2023

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.1354 To 1357/Kol/2024 Assessment Years: 2018-19, 2019-20, 2020-21, 2022-23 Manas……….…….… ……….. ……..……………………....Appellant 14, Rbi Green Wood Nook, 369/2, Purbachal, Kalitala Road, Kolkata – 700078. [Pan: Aabam3353Q] Vs. Ito, Ward-1(4), Exemption, Kolkata............................…..…..... Respondent Appearances By: Shri G. Banerjee, Fca, Appeared On Behalf Of The Appellant. Shri Rajat Datta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 03, 2024 Date Of Pronouncing The Order : December 04, 2024 आदेश / Order Per Bench: The Above Captioned Appeals Filed By The Assessee Against The Order Of The Commissioner Of Income Tax, Appeal Addl/Jcit(A)-2, Jaipur [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Pertaining To Four Assessment Years I.E 2018-19, 2019-20, 2020-21 & 2022-23 Respectively. Since, The Issues Involved In All These Appeals Arise From Common Set Of Facts & Related To Same Party, Therefore, These Have Been Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience, Brevity & Clarity. Since The Grounds In All Appeals Are Identical, Except Change Of Figures, The First Appeal Being Ita No.1354/Kol/2024 For Assessment Year 2018-19 Is Taken As Lead Case.

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

Assessing Officer with a direction to the Assessing Officer to reexamine the issue afresh in accordance with law after giving reasonable opportunity of being heard to the assessee. 5. On the other hand, the ld. DR opposed to the condonation of delay and argued that the assessee did not demonstrate ... 1357/Kol/2024 Assessment Years: 2018-19, 2019-20, 2020-21, 2022-23 MANAS considered as entirely satisfactory. We also feel that denial of opportunity of being heard on merits would cause irreparable injustice to the assessee. We also note that the merit of the case should not be ignored

Manas, Kolkata vs. I.T.O., Ward - 1(4), Exemption, Kolkata

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

ITA 1356/KOL/2024[2020-2021]Status: DisposedITAT Kolkata04 Dec 2024AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.1354 To 1357/Kol/2024 Assessment Years: 2018-19, 2019-20, 2020-21, 2022-23 Manas……….…….… ……….. ……..……………………....Appellant 14, Rbi Green Wood Nook, 369/2, Purbachal, Kalitala Road, Kolkata – 700078. [Pan: Aabam3353Q] Vs. Ito, Ward-1(4), Exemption, Kolkata............................…..…..... Respondent Appearances By: Shri G. Banerjee, Fca, Appeared On Behalf Of The Appellant. Shri Rajat Datta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 03, 2024 Date Of Pronouncing The Order : December 04, 2024 आदेश / Order Per Bench: The Above Captioned Appeals Filed By The Assessee Against The Order Of The Commissioner Of Income Tax, Appeal Addl/Jcit(A)-2, Jaipur [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Pertaining To Four Assessment Years I.E 2018-19, 2019-20, 2020-21 & 2022-23 Respectively. Since, The Issues Involved In All These Appeals Arise From Common Set Of Facts & Related To Same Party, Therefore, These Have Been Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience, Brevity & Clarity. Since The Grounds In All Appeals Are Identical, Except Change Of Figures, The First Appeal Being Ita No.1354/Kol/2024 For Assessment Year 2018-19 Is Taken As Lead Case.

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

Assessing Officer with a direction to the Assessing Officer to reexamine the issue afresh in accordance with law after giving reasonable opportunity of being heard to the assessee. 5. On the other hand, the ld. DR opposed to the condonation of delay and argued that the assessee did not demonstrate ... 1357/Kol/2024 Assessment Years: 2018-19, 2019-20, 2020-21, 2022-23 MANAS considered as entirely satisfactory. We also feel that denial of opportunity of being heard on merits would cause irreparable injustice to the assessee. We also note that the merit of the case should not be ignored

Manas, Kolkata vs. I.T.O., Ward - 1(4), Kolkata

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

ITA 1355/KOL/2024[2019-2020]Status: DisposedITAT Kolkata04 Dec 2024AY 2019-2020

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.1354 To 1357/Kol/2024 Assessment Years: 2018-19, 2019-20, 2020-21, 2022-23 Manas……….…….… ……….. ……..……………………....Appellant 14, Rbi Green Wood Nook, 369/2, Purbachal, Kalitala Road, Kolkata – 700078. [Pan: Aabam3353Q] Vs. Ito, Ward-1(4), Exemption, Kolkata............................…..…..... Respondent Appearances By: Shri G. Banerjee, Fca, Appeared On Behalf Of The Appellant. Shri Rajat Datta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 03, 2024 Date Of Pronouncing The Order : December 04, 2024 आदेश / Order Per Bench: The Above Captioned Appeals Filed By The Assessee Against The Order Of The Commissioner Of Income Tax, Appeal Addl/Jcit(A)-2, Jaipur [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Pertaining To Four Assessment Years I.E 2018-19, 2019-20, 2020-21 & 2022-23 Respectively. Since, The Issues Involved In All These Appeals Arise From Common Set Of Facts & Related To Same Party, Therefore, These Have Been Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience, Brevity & Clarity. Since The Grounds In All Appeals Are Identical, Except Change Of Figures, The First Appeal Being Ita No.1354/Kol/2024 For Assessment Year 2018-19 Is Taken As Lead Case.

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

Assessing Officer with a direction to the Assessing Officer to reexamine the issue afresh in accordance with law after giving reasonable opportunity of being heard to the assessee. 5. On the other hand, the ld. DR opposed to the condonation of delay and argued that the assessee did not demonstrate ... 1357/Kol/2024 Assessment Years: 2018-19, 2019-20, 2020-21, 2022-23 MANAS considered as entirely satisfactory. We also feel that denial of opportunity of being heard on merits would cause irreparable injustice to the assessee. We also note that the merit of the case should not be ignored

Manas, Kolkata vs. I.T.O., Ward - 1(4), Exemption, Kolkata

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

ITA 1354/KOL/2024[2018-2019]Status: DisposedITAT Kolkata04 Dec 2024AY 2018-2019

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.1354 To 1357/Kol/2024 Assessment Years: 2018-19, 2019-20, 2020-21, 2022-23 Manas……….…….… ……….. ……..……………………....Appellant 14, Rbi Green Wood Nook, 369/2, Purbachal, Kalitala Road, Kolkata – 700078. [Pan: Aabam3353Q] Vs. Ito, Ward-1(4), Exemption, Kolkata............................…..…..... Respondent Appearances By: Shri G. Banerjee, Fca, Appeared On Behalf Of The Appellant. Shri Rajat Datta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 03, 2024 Date Of Pronouncing The Order : December 04, 2024 आदेश / Order Per Bench: The Above Captioned Appeals Filed By The Assessee Against The Order Of The Commissioner Of Income Tax, Appeal Addl/Jcit(A)-2, Jaipur [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Pertaining To Four Assessment Years I.E 2018-19, 2019-20, 2020-21 & 2022-23 Respectively. Since, The Issues Involved In All These Appeals Arise From Common Set Of Facts & Related To Same Party, Therefore, These Have Been Heard Together & Are Being Disposed Of By This Consolidated Order For The Sake Of Convenience, Brevity & Clarity. Since The Grounds In All Appeals Are Identical, Except Change Of Figures, The First Appeal Being Ita No.1354/Kol/2024 For Assessment Year 2018-19 Is Taken As Lead Case.

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

Assessing Officer with a direction to the Assessing Officer to reexamine the issue afresh in accordance with law after giving reasonable opportunity of being heard to the assessee. 5. On the other hand, the ld. DR opposed to the condonation of delay and argued that the assessee did not demonstrate ... 1357/Kol/2024 Assessment Years: 2018-19, 2019-20, 2020-21, 2022-23 MANAS considered as entirely satisfactory. We also feel that denial of opportunity of being heard on merits would cause irreparable injustice to the assessee. We also note that the merit of the case should not be ignored

K. Adirajan, Chennai vs. ITO, Ncw-4(1), Chennai

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

ITA 2316/CHNY/2024[2017-18]Status: DisposedITAT Chennai04 Dec 2024AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.2316/Chny/2024 िनधा:रण वष: /Assessment Year: 2017-18 K. Adirajan, The Income Tax Officer, New No.19, Old No.35, Vs. Non Corporate Ward-4(1), Ramanuja Iyer Street, Chennai. Old Washermenpet, Chennai – 600 021. [Pan: Aaipr 6303D]

For Appellant: NoneFor Respondent: Mrs. G. Saratha, Addl. CIT
Section 143(3)Section 250(6)Section 69

parte order in confirming the addition on cash deposits of Rs. 33,00,000/- u/s. 69 of the Act without giving adequate opportunity of being heard. 4. The assessee is an individual and has deposited cash of Rs.33,00,000/- in his saving bank account with Central Bank of India

Mahadevan, Tambaram vs. ITO, Non Corp. Ward 22(1), Tambaram

In the result the appeal filed by the assesse is allowed for statistical purposes

ITA 2223/CHNY/2024[2019-20]Status: DisposedITAT Chennai04 Dec 2024AY 2019-20

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./ Ita No.2223 /Chny/2024 निर्ाारण वर्ा /Assessment Years: 2019-20 Mahadevan, Income Tax Officer, No.23, 2Nd Lane, 1, New Market, Non-Corporate Ward-22(1), Tambaram West, Chennai. Chennai-600 045. [Pan: Alhpm7502K] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri G.Akash, Advocate प्रत्यर्थी की ओर से /Revenue By : Mr.Chinthapalli Meher Chand, Jcit सुिवाई की तारीख/Date Of Hearing : 21.10.2024 घोर्णा की तारीख /Date Of Pronouncement : 04.12.2024 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Shri G.Akash, AdvocateFor Respondent: Mr.Chinthapalli Meher Chand, JCIT
Section 250

matter de novo after considering details filed by the assessee in accordance with law and by passing of a speaking order due opportunity of being heard shall be given to assessee. The assessee shall be responsible to comply with all the notices issued by Ld. Frist Appellate Authority

Dashrath Singh, Jaipur vs. Income Tax Officer Ward Behror, Behrod

18. As a result, this second mentioned appeal- ITA No

ITA 1197/JPR/2024[2011-12]Status: DisposedITAT Jaipur04 Dec 2024AY 2011-12

Bench: SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Ravi Kumar Bansal, CAFor Respondent: Shri Gautam Singh Choudhary (JCIT), DR
Section 144Section 147Section 148Section 250Section 271(1)(c)

claim put forth by the assessee for the first time before the ld. CIT(A),we find that the assesse deserves another opportunity of being heard before the AO to produce all the relevant documents to explain cash deposit of Rs.8,03,200/-, which according to the authorities below remained ... result, this appeal No. 1197/JPR/2024 is disposed of for statistical purposes and matter is remanded back for adjudication afresh, after providing an opportunity of being heard to the assessee, as regards the cash deposit of Rs.8,03,200/-. SHRI DASHRATH SINGH VS ITO, WARD-BEHROR The assessee is burdened with

M/S. Mjn Foundation, Bangalore vs. The Commissioner of Income Tax( Exemptions), Bengaluru

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

ITA 2029/BANG/2024[N/A]Status: DisposedITAT Bangalore04 Dec 2024

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : Na M/S. Mjn Foundation, Vs. Cit (Exemptions), No.32, Yesshodanagar Near Jakkur, Bengaluru. Plantation Airport Road, Yelahanka, Gkvk, Bengaluru – 560 064. Pan : Aapcm 5819 D Appellant Respondent Assessee By : Shri. V. Srinivasan, Advocate. Revenue By : Shri. Subramanian, Jcit(Dr)(Itat), Bengaluru. Date Of Hearing : 28.11.2024 Date Of Pronouncement : 04.12.2024 O R D E R Per Laxmi Prasad Sahuthis Appeal Is Filed By The Assessee Against The Order Passed By The Cit(E) Dated 26.09.2024 For Not Granting Approval Under Section 80G(V) Of The Act, Observing That The Assessee Was Unable To Submit Necessary Documents To Prove The Genuineness Of The Activities Of The Trust Or Institution & Non-Fulfillment Of All The Conditions Laid Down In Clauses 1 To 5 Under Section 80G Of The Act.

For Appellant: Shri. V. Srinivasan, AdvocateFor Respondent: Shri. Subramanian, JCIT(DR)(ITAT), Bengaluru
Section 12ASection 80G

filed Form No.10AB dated 29.03.2024 for approval under section 80G(v) of the Act and assessee was granted opportunity of being heard and was issued two notices on 22.07.2024 & 23.08.2024, but we noted that as per the Order of the CIT(E), assessee could not comply with the notices ... that would be essential and required for substantiating its case and for proper adjudication by the CIT (E). Needless to say that reasonable opportunity of being heard be given to the assessee. The assessee is directed to cooperate with the Page 3 of 3 proceedings and in case of further

Mrs. Sabena Prakash, Bengaluru vs. Income Tax Officer, Ward-3(2)(1), Bangalore

In the result, appeal filed by the assessee is partly allowed

ITA 1480/BANG/2024[2018-19]Status: DisposedITAT Bangalore04 Dec 2024AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubey

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 234BSection 250Section 270ASection 274Section 44A

shall allow all the relevant expenditure incurred with respect to said activities in accordance with law. Needless to say the reasonable opportunity of being heard must be provided to the assessee. It is ordered accordingly. 7. In the result, appeal filed by the assessee is partly allowed. Order pronounced

Madhav Sheth, Golf Course Road, Gurgaon vs. Central Circle 6(1), Mumbai, Air India Building

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

ITA 5064/MUM/2024[2017-18]Status: DisposedITAT Mumbai04 Dec 2024AY 2017-18

Bench: Shri Saktijit Dey, Hon’Ble & Shri Amarjit Singh, Hon’Bleassessment Year: 2017-18 Madhav Sheth Central Circle-6(1), Mumbai B-81, Golf Course Road, The Vs Pinnacle Dlf City, Phase-V, Sector- 43, Gurgaon, Haryana-122009. Pan: Ajaps 4139 D (Appellant) (Respondent)

For Appellant: Ms. Kavita NaberaFor Respondent: Smt. Sanyogita Nagpal, CIT, DR
Section 69A

circumstances of the Appellant's case and in law the Ld. CIT(A) erred in passing an ex-parte order without giving reasonable opportunity of being heard, for the reasons mentioned in the impugned order or otherwise. 2. On the facts and circumstances of Appellant's case

Chaitalee Sachin Deokar, Mumbai vs. Commissioner of Income Tax, -It -2, Mumbai

In the result, both the appeals filed by the assessee are

ITA 2806/MUM/2024[2013-14]Status: DisposedITAT Mumbai04 Dec 2024AY 2013-14

Bench: Shri Sandeep Gosain & Ms. Padmavathy S

Section 143(3)Section 263Section 69Section 69BSection 69C

interest of the revenue within the meaning of section 263 of the Income-tax Act. 1961 and the assessee was allowed an opportunity of being heard and to show cause as to why an order enhancing or modifying the assessment or cancelling the assessment and directing a fresh assessment within

Blue Ocean Travels Pvt. Ltd., Delhi vs. DCIT, Central Circle-15, Delhi

In the result, all the appeals filed by the assessee relevant to AYs 2014-15 to 2020-21 are allowed

ITA 3287/DEL/2024[2020-21]Status: DisposedITAT Delhi04 Dec 2024AY 2020-21

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S., Judicialmember

For Appellant: Shri Amit Goel, CAFor Respondent: Ms. Amisha S. Gupt, CIT DR
Section 127Section 132Section 132(4)Section 133ASection 142(1)Section 143(2)Section 153C

facts and circumstances of the case and in law, the CIT(A) erred in passing ex-parte order without providing proper opportunity of being heard. 8. On the facts and circumstances of the case and in law, the CIT (A) erred in not adjudicating the grounds of appeal on merit

Blue Ocean Travels Pvt. Ltd., Delhi vs. DCIT, Central Circle - 15, Delhi

In the result, all the appeals filed by the assessee relevant to AYs 2014-15 to 2020-21 are allowed

ITA 3286/DEL/2024[2019-20]Status: DisposedITAT Delhi04 Dec 2024AY 2019-20

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S., Judicialmember

For Appellant: Shri Amit Goel, CAFor Respondent: Ms. Amisha S. Gupt, CIT DR
Section 127Section 132Section 132(4)Section 133ASection 142(1)Section 143(2)Section 153C

facts and circumstances of the case and in law, the CIT(A) erred in passing ex-parte order without providing proper opportunity of being heard. 8. On the facts and circumstances of the case and in law, the CIT (A) erred in not adjudicating the grounds of appeal on merit

Blue Ocean Travels Pvt. Ltd., Delhi vs. DCIT, Central Circle - 15, Delhi

In the result, all the appeals filed by the assessee relevant to AYs 2014-15 to 2020-21 are allowed

ITA 3285/DEL/2024[2018-19]Status: DisposedITAT Delhi04 Dec 2024AY 2018-19

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S., Judicialmember

For Appellant: Shri Amit Goel, CAFor Respondent: Ms. Amisha S. Gupt, CIT DR
Section 127Section 132Section 132(4)Section 133ASection 142(1)Section 143(2)Section 153C

facts and circumstances of the case and in law, the CIT(A) erred in passing ex-parte order without providing proper opportunity of being heard. 8. On the facts and circumstances of the case and in law, the CIT (A) erred in not adjudicating the grounds of appeal on merit

Blue Ocean Travels Pvt. Ltd., Delhi vs. DCIT, Central Circle-15, Delhi

In the result, all the appeals filed by the assessee relevant to AYs 2014-15 to 2020-21 are allowed

ITA 3284/DEL/2024[2017-18]Status: DisposedITAT Delhi04 Dec 2024AY 2017-18

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S., Judicialmember

For Appellant: Shri Amit Goel, CAFor Respondent: Ms. Amisha S. Gupt, CIT DR
Section 127Section 132Section 132(4)Section 133ASection 142(1)Section 143(2)Section 153C

facts and circumstances of the case and in law, the CIT(A) erred in passing ex-parte order without providing proper opportunity of being heard. 8. On the facts and circumstances of the case and in law, the CIT (A) erred in not adjudicating the grounds of appeal on merit

Blue Ocean Travels Pvt .Ltd., Delhi vs. DCIT, Central Circle -15, Delhi

In the result, all the appeals filed by the assessee relevant to AYs 2014-15 to 2020-21 are allowed

ITA 3283/DEL/2024[2016-17]Status: DisposedITAT Delhi04 Dec 2024AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S., Judicialmember

For Appellant: Shri Amit Goel, CAFor Respondent: Ms. Amisha S. Gupt, CIT DR
Section 127Section 132Section 132(4)Section 133ASection 142(1)Section 143(2)Section 153C

facts and circumstances of the case and in law, the CIT(A) erred in passing ex-parte order without providing proper opportunity of being heard. 8. On the facts and circumstances of the case and in law, the CIT (A) erred in not adjudicating the grounds of appeal on merit