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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

Shri Hari & Co Owners, Kaithal vs. Pr. CIT, Chandigarh -1, Rohtak

In the result, both the above appeals of the Assessee are dismissed

ITA 403/CHANDI/2022[2013-14]Status: DisposedITAT Chandigarh31 Jul 2024AY 2013-14

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

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 263

erroneous in so far as it is prejudicial to the interest of the revenue, he may, after giving the assesse an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify ... with the direction to pass an order afresh, in accordance with law keeping in view the observations made above and after affording reasonable opportunity of being heard to the assessee.” 8. The Ld. PCIT before holding as above by following the due process had called for and examined the record

Shri Hari & Co Owners, Kaithal vs. Pr. CIT, Chandigarh -1, Rohtak

In the result, both the above appeals of the Assessee are dismissed

ITA 402/CHANDI/2022[2012-13]Status: DisposedITAT Chandigarh31 Jul 2024AY 2012-13

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

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Smt. Kusum Bansal, CIT DR
Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 263

erroneous in so far as it is prejudicial to the interest of the revenue, he may, after giving the assesse an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify ... with the direction to pass an order afresh, in accordance with law keeping in view the observations made above and after affording reasonable opportunity of being heard to the assessee.” 8. The Ld. PCIT before holding as above by following the due process had called for and examined the record

Chandrakant Gordhanbhai Patel HUF, Dabhoi vs. The Dy. Commissioner of Income Tax Circle-1(3), Vadodara

In the result, appeal of the assessee in ITA no

ITA 485/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad31 Jul 2024AY 2012-13

Bench: The Final Hearing Of This Appeal Petition…”

For Appellant: None(Written Submission filed by the assessee)For Respondent: Shri Sanjay Jain, Sr. D.R
Section 139Section 142(1)Section 143(2)Section 144Section 147Section 148Section 250

Page No. 19 Chandrkant Gordhanbhai Patel v. DCIT and adjudicated on merits in accordance with law . The AO shall give proper and adequate opportunity of being heard to the assessee during denovo reassessment proceedings. The AO is directed to pass speaking and reasoned order . The assessee on its part

Sachin Shantilal Runwal, Dhule vs. Income-Tax Officer Ward-2, Dhule

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

ITA 885/PUN/2024[201718]Status: DisposedITAT Pune31 Jul 2024

Bench: SHRI G. D. PADMAHSHALI (Accountant Member), SHRI VINAY BHAMORE (Judicial Member)

For Appellant: NoneFor Respondent: Shri Umashankar Prasad
Section 115BSection 142(1)Section 144Section 2Section 250Section 68Section 69ASection 80T

claimed by the assessee. LD CIT(A)/NFAC shall pass the order a fresh as per facts & law after providing reasonable opportunity of being heard to the assessee. The assessee is also directed to appear/ respond on the date fixed for hearing & explain his case without taking adjournment under

Sheetal Sandeep Meher, Jalgaon vs. ITO, Ward1(2), Jalgaon

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

ITA 1000/PUN/2024[2013-14]Status: DisposedITAT Pune31 Jul 2024AY 2013-14

Bench: Shri G. D. Padmahshali & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1000/Pun/2024 िनधा"रण वष" / Assessment Year : 2013-14 Sheetal Sandeep Meher, Vs. Ito, Ward-1(2), 3Rd Floor, Pitruchaya Jalgaon. Building, Nehru Chowk, Navi Peth, Jalgaon- 425001. Pan : Aqupm5982D Appellant Respondent Assessee By : Shri Sanket Joshi Revenue By : Shri Umashankar Prasad Date Of Hearing : 22.07.2024 Date Of Pronouncement : 31.07.2024 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.02.2024 Passed By Ld Cit(A)/Nfac For The Assessment Year 2013-14. 2. The Present Appeal Is Filed Belatedly I.E. With The Delay Of 13 Days. The Appellant Furnished An Affidavit Praying For Condonation Of Delay In The Circumstances Mentioned Therein.

For Appellant: Shri Sanket JoshiFor Respondent: Shri Umashankar Prasad
Section 10(38)Section 115BSection 142(1)Section 143(3)Section 147Section 148Section 151Section 271(1)(c)

mehersandeep@rediffmail.com and instead, issuing the notice on a different email id i.e. meherpranav5@gmail.com and thus, the said appellate order passed without granting proper opportunity of being heard, may be declared as null and void in law. 2. Without prejudice to ground no. 1, the assessee submits that the learned ... opportunity of hearing to the assessee. The ld. CIT(A)/NFAC shall pass the order as per facts and law after providing reasonable opportunity of being heard to the assessee. The assessee is also hereby directed to respond to the notice issued 6 by Ld. CIT(A)/NFAC and submit

Shree Estates, Hyderabad vs. Income Tax Officer, Ward-14(1), Hyderabad

ITA 469/HYD/2023[2018-19]Status: DisposedITAT Hyderabad31 Jul 2024AY 2018-19

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.469/Hyd/2023 (िनधा"रण वष"/Assessment Year: 2018-19) Shree Estates Vs. Income Tax Officer Hyderabad Ward 14(1) Pan:Adifs9997B Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V. Prasad, Ca राज" व "ारा/Revenue By:: Shri Kumar Pranav, Cit(Dr) सुनवाई की तारीख/Date Of Hearing: 09/07/2024 घोषणा की तारीख/Pronouncement: 31/07/2024 आदेश/Order

For Appellant: Shri M.V. Prasad, CAFor Respondent: : Shri Kumar Pranav, CIT(DR)
Section 68

compute the correct fair market value of the asset in accordance with other methods as provided by the Act/Rules after affording reasonable opportunity of being heard to the assessee. The act has consciously used different terminology in different provisions of the Act. For example, the provisions of section

Kammela Srinivasara Rao, Tenali vs. The Income Tax Officer, Ward-1, Tenali

In the result, appeal of the assessee is allowed for statistical purposes as indicated herein above

ITA 73/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam31 Jul 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./ I.T.A. No.73/Viz/2024 (िनधा"रण वष" / Assessment Year : 2017-18) Kammela Srinivasara Rao, Vs. The Income Tax Officer, D.No. 7-14-9, Harikrishna Ward-1, Medical Agencies, Battavari Tenali. Street, Ganganammapet, Tenali, Andhra Pradesh. Pan: Akzpk3519M (अपीलाथ"/ Appellant) (""यथ"/ Respondent) अपीलाथ" क" ओर से/ Appellant By : Sri Gvn Hari, Ar ""याथ" क" ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar सुनवाई क" तारीख / Date Of Hearing : 04/06/2024 घोषणा क" तारीख/Date Of : 31/07/2024 Pronouncement O R D E R

For Appellant: Sri GVN Hari, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 133ASection 139(4)Section 142(1)Section 144Section 208Section 234B(1)Section 249(4)(b)Section 271ASection 69A

matter back to the file of the Ld.CIT(A)-NFAC with a direction to decide the case on merits after affording a reasonable opportunity of being heard to the assessee in accordance with the principles of natural justice. 8 At the same breath, I also hereby caution the assessee

Jami Pradhamika Vyavasayasharakara Parapathi Sangham Ltd., Vizianagaram vs. Income-Tax Officer, Vizianagaram

In the result, appeal of the assessee is allowed for statistical purposes as indicated herein above

ITA 206/VIZ/2024[2016-17]Status: DisposedITAT Visakhapatnam31 Jul 2024AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./ I.T.A. No. 206/Viz/2024 (िनधा"रण वष" / Assessment Year : 2016-17) Jami Pradhamika Vyavasaya Vs. Income Tax Officer, Sahakara Parapathi Vizianagaram. Sanghamltd., Vizianagaram. Pan: Aabaj1927F (अपीलाथ"/ Appellant) (""थ"/ Respondent) अपीलाथ" की ओर से/ Appellant By : Sri I. Kama Sastry, Ar ""ाथ" की ओर से / Respondent By : Dr. Aparna Villuri, Sr. Ar

For Appellant: Sri I. Kama Sastry, ARFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 133(6)Section 142(1)Section 144Section 147Section 148Section 249(3)Section 69A

file of the Ld. CIT(A)-NFAC with a direction to dispose of the appeal on merits after affording a reasonable opportunity of being heard to the assessee in accordance with the principles of natural justice. Further, we also hereby caution the assessee to cooperate before

Mubaise Parayil, Iritty vs. Income Tax Officer, Ward 3, Kannur

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

ITA 383/COCH/2025[2018-19]Status: DisposedITAT Cochin31 Jul 2024AY 2018-19

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

Section 133(6)Section 147Section 148Section 69A

restore the entire matter back to the file of the CIT(A) for de novo adjudication, after affording the assessee a reasonable opportunity of being heard and to file necessary documents to substantiate its case. 8. In the result, the appeal of the assessee is allowed for statistical purposes. 31st

Elanthoor Service Co-Operative Bank Ltd, Elanthoor vs. ITO, Ward -2, Thiruvalla

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

ITA 290/COCH/2025[2022-23]Status: DisposedITAT Cochin31 Jul 2024AY 2022-23

Bench: Shri Inturi Rama Rao & Shri Sonjoy Sarma

Section 142(1)Section 143(3)Section 80P

Assessing Officer with a direction I.T.A. No.290/COCH/2025 Elanthoor Service Co-Operative Bank Ltd to examine the issue afresh after affording reasonable opportunity of being heard. The assessee is also directed to fully cooperate and produce all relevant documents to substantiate its claims. 7. In the result, the appeal

Annamma Joseph, Pathanamthitta vs. The Income Tax Officer, Ward-2(5), Bhopal, Madhya Pradesh, Kerala

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

ITA 233/IND/2024[2015-16]Status: DisposedITAT Indore31 Jul 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri B.M. Biyaniannamma Joseph Ito-2(5) 1088, Zion Villa Bhopal Thottapuzhassery, Pullad S.O. Vs. Pathanamthitta Kerala (Appellant / Assessee) (Respondent/ Revenue) Pan: Adlpj3534G Assessee By None Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 31.07.2024 Date Of Pronouncement 31.07.2024

Section 147Section 249(4)Section 249(4)(b)

merits of the case. Needles to say, the CIT( Appeals) shall in the course of the set-aside proceedings afford a reasonable opportunity of being heard to the assessee.” 8. Accordingly, to maintain the rule of consistency we follow the earlier decisions of the Tribunal cited above and consequently

Manda Dubey, Hoshangabad vs. Income Tax Officer Itrasi, Itrasi

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

ITA 228/IND/2024[2017-18]Status: DisposedITAT Indore31 Jul 2024AY 2017-18

Bench: Shri Manish Boradmanda Dubey, Ito, Ganeshganj

Section 143Section 143(2)Section 144Section 147Section 148Section 151Section 69A

explaining the source of alleged cash deposit of Rs.12,60,000/- to the file of A.O for deciding it afresh for which reasonable opportunity of being heard to be provided to the assessee and also Ld. A.O is directed to entertain the additional evidence to be filed by the assessee

Shivam Enterprises, Harda vs. National Faceless Assessment Centre, Delhi

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

ITA 224/IND/2024[2016-17]Status: DisposedITAT Indore31 Jul 2024AY 2016-17

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanishivam Enterprises Nfac 483, Lal Bangla, Lal Bhadhur Delhi Shastri Ward Vs. Tahsil Harda Harda (Appellant / Assessee) (Respondent/ Revenue) Pan: Acdfs1727R Assessee By Ms. Nisha Lahoti, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 31.07.2024 Date Of Pronouncement 31 .07.2024

Section 142(3)Section 148Section 153CSection 69A

section 142(3) by not providing the information and documents gathered which formed the basis of inquiry and in the absence of an opportunity of being heard given to the assessee in respect such gathered material 5. On the facts and circumstances of the case and applicable ... 115BBE of Rs. 5,83,27,676 as undisclosed money arising out of unexplained receipt of income without giving sufficient opportunity of being heard 10. The appellant craves leave to add, amend, alter or otherwise raise any other ground of appeal.” 2. At the time of hearing

Govindaswamy Chitra Sivaraj, Coimbatore vs. ITO, Corp Circle 1, Coimbatore

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

ITA 1416/CHNY/2024[2015-16]Status: DisposedITAT Chennai31 Jul 2024AY 2015-16

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No.1416/Chny/2024 िनधा9रण वष9 /Assessment Year: 2015-16

For Appellant: Ms. Divya Abhishek Murali, C.A HIFor Respondent: Shri V. Nandakumar, CIT
Section 147

parte. Therefore, we are of the opinion that keeping in mind the principles of natural justice, the assessee be provided with another opportunity of being heard. We accordingly remand the matter back to the file of the Ld. CIT(A) to adjudicate this appeal afresh in accordance with law subject

Singarayan Bharathi Florance Jasmine, Coimbatore vs. ITO, Ncw 5(2), Coimbatore

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

ITA 1400/CHNY/2024[2010-11]Status: DisposedITAT Chennai31 Jul 2024AY 2010-11

Bench: Shri Manu Kumar Giri & Shri Jagadishआयकर अपील सं./Ita No.1400/Chny/2024 िनधा8रण वष8 /Assessment Year: 2010-11

For Appellant: Shri I. Dinesh, Advocate for Shri Y. Sridhar, C.A FGFor Respondent: Shri V. Nandakumar, CIT
Section 143(3)

notices. We are of the opinion that keeping in mind the principles of natural justice, the assessee be provided with another opportunity of being heard. Therefore, we deem it proper to remand the matter back to the file of the Ld. CIT(A) to adjudicate this appeal afresh in accordance

Silver Wings Life Spaces, Kota vs. DCIT Circle-1 Kota, Kota

In the result, the appeal of the assessee is allowed

ITA 511/JPR/2024[2017-18]Status: DisposedITAT Jaipur31 Jul 2024AY 2017-18

Bench: Learned Cit(A), Which Appeal Was Filed By The Assessee

For Appellant: Sh. Shrawan Kumar Gupta, AdvFor Respondent: Sh. A. S. Nehra(Addl. CIT)
Section 115BSection 143(3)Section 145(3)Section 234ASection 69

upon the assessee through registered e-mail by ITBA on 01.09.2018 andalso by registered post. 3.1 Due to change of incumbent, a fresh opportunity of being heard was given by ld. AO u/s 129 of the IT Act, on 05.08.2015. Further, a notice u/s 4 Silver Wings Life Spaces

Om Infra Limited, Jaipur Rajasthan vs. DCIT, Central Circle-1, Jaipur, Rajasthan

In the result, we find no substantial question of law being involved in this appeal

ITA 811/JPR/2023[2015-16]Status: DisposedITAT Jaipur31 Jul 2024AY 2015-16

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Sh. P. C. Parwal (CA)For Respondent: Sh. A. S. Nehra (Addl. CIT)
Section 115JSection 143(3)Section 154Section 80Section 801C(2)(b)Section 80I

which the assessee contended before us as not received and thereby contended that the order is passed without affording the proper opportunity of being heard to the assessee. Thus, the contention of the ld. AO that the assessee neither attended nor filed any reply in connection with those notices

Sharanabasappa Bapugowda Patil, Kalaburagi vs. ACIT, Circle 1(3)(1), Bengaluru

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

ITA 942/BANG/2024[2014-2015]Status: DisposedITAT Bangalore31 Jul 2024AY 2014-2015

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeysharanabasappa Bapugowda Patil Acit, Circle - 1(3)(1) No. 18, Khb Colony 6Th Floor, Hmt Bhavan Benhind Court Kalaburagi Vs. Ballari Road Karnataka 585102 Bengaluru 560032 Pan – Abypd4489M (Appellant) (Respondent) Assessee By: Shri Vinod S. Joshi, Ca Revenue By: Shri V. Parithivel, Jcit-Dr

For Appellant: Shri Vinod S. Joshi, CAFor Respondent: Shri V. Parithivel, JCIT-DR
Section 250

file of ld. CIT(A) for fresh consideration and to decide the issue in accordance with law after granting the assessee adequate opportunity of being heard. The assessee is also directed to cooperate with the proceeding before the ld. CIT(A)/NFAC & to file the necessary submissions/ documents/evidences & satisfy them

Gomaram Choudhary, Rajasthan vs. Assistant Commissioner of Income Tax, Circle-5(2)(1), Bangalore

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

ITA 822/BANG/2024[2017-18]Status: DisposedITAT Bangalore31 Jul 2024AY 2017-18

Bench: Shri Chandra Poojari & Shri Keshav Dubey

For Appellant: Sri.Vishwa Padmanabhan, CAFor Respondent: Sri.Ganesh R.Gale, Standing Counsel
Section 143(3)Section 250Section 253(5)Section 69

remit the matter to the file of the CIT(A) for fresh consideration and decision as per law after affording a reasonable opportunity of being heard to the assessee. The assessee is directed to produce all the necessary documents / records in support of his case and shall not seek unnecessary

Madhuri Bhattacharya, Bangalore vs. Assistant Commissioner of Income Tax, Circle-2(3)(1), Bangalore

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

ITA 630/BANG/2024[2013-14]Status: DisposedITAT Bangalore31 Jul 2024AY 2013-14

Bench: Shri Chandra Poojari & Shri Keshav Dubeymadhuri Bhattacharya Acit, Circle 2(3)(1) No. 363, 11Th Cross Bmtc Building 4Th Main Road, 2Nd Block Vs. Koramangala R.T. Nagar, Bangalore 560032 Bangaore 560095 Pan – Ahepb0337N (Appellant) (Respondent) Assessee By: Shri Deepak Chopra, Ca Revenue By: Shri V. Parithivel, Jcit-Dr Date Of Hearing: 13.05.2024 Date Of Pronouncement: 31.07.2024 O R D E R Per: Keshav Dubey, J.M. This Appeal At The Instance Of The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 27.02.2024 Vide Din & Order No. Itba/Nfac/S/250/2003-24/1061593922(1) Passed Under Section 250 Of The Income Tax Act, 1961 (The Act) In Respect Of Assessment Year (Ay) 2013-14. 2. The Assessee Has Raised The Following Grounds Of Appeal: - “1. The Orders Of Lower Authorities Are Bad In Law & Liable To Be Quashed For: A) Non-Consideration Of Material On Record & Submissions Of The Appellant B) Want Of Application Of Principles Of Natural Justice. Without Prejudice: 2. The Learned Assessing Officer Has Erred In Making An Addition Of Rs. 1,93,00,000 As Unexplained Investment & 36,00,000 As Expenditure Not Related To The Profession Without Issuing A Show Cause Notice As Mandated

For Appellant: Shri Deepak Chopra, CAFor Respondent: Shri V. Parithivel, JCIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 234BSection 234CSection 250

Email. Further the ld. Counsel of the assessee vehemently submitted that the order passed by the ld. CIT(A) without providing opportunity of being heard is gross violation of the principles of natural justice. Further the learned A.R. of 4 Madhuri Bhattacharya the assessee drew our attention to page ... issue involved in the present appeal is restored to the file of the ld. CIT(A) for fresh adjudication after granting adequate opportunity of being heard to the assessee. The assessee shall produce all the necessary documents/evidences in support of her case and shall not seek unnecessary adjournments. In case