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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

Arun Babulal Shah, Mumbai vs. CIT Appeal, NFAC

In the result, appeal of the assesseeITA 2460/Mum/2023 is partly allowed

ITA 2460/MUM/2023[2012-2013]Status: DisposedITAT Mumbai09 Jul 2024AY 2012-2013

Bench: Shri Prashant Maharshi & Shri Anikesh Banerjee

For Appellant: Shri Arun B ShahFor Respondent: Shri Manoj Kumar SinhaSR.DR
Section 143(3)Section 250

amount of Rs.56,08,404/- is also remitted back to the file of Ld.AO. Needless to say, the assessee should get a reasonable opportunity of being heard in set aside proceedings. 8. In our considered view, the appeal of the assesseeGround no-1 is partly allowed for statistical purpose, Ground

Calcom Institute of Management Development and Training, New Delhi vs. CIT(Exemption), New Delhi

In the result, the appeal of the assessee is allowed

ITA 1751/DEL/2024[2018-19]Status: DisposedITAT Delhi09 Jul 2024AY 2018-19

Bench: Shri Saktijit Dey, Hon’Ble & Shri M. Balaganeshcalcom Institute Of Vs. Cit(Exemption), Management Development & New Delhi Training, C-41, Defence Colony, New Delhi (Appellant) (Respondent) Pan:Aaatc0685K Assessee By : Shri Salil Aggarwal, Sr. Adv Shri Shailesh Gupta, Ca Shri Madhur Aggarwal, Adv Revenue By: Ms. Rajinder Kaur, Cit Dr Date Of Hearing 03/07/2024 Date Of Pronouncement 09/07/2024

For Appellant: Shri Salil Aggarwal, Sr. AdvFor Respondent: Ms. Rajinder Kaur, CIT DR
Section 11Section 12ASection 143(3)Section 144BSection 263

investigation wherever required. Needless to say that the matter may Calcom Institute of Management Development and Training be decided after affording reasonable opportunity of being heard to the assessee and pass a speaking and well-reasoned order.” 6. We find that at the outset, the trust has not paid

D K S Shiksha Prasar Samiti, Meerut vs. ACIT, Circle-1(1)(1), Meerut

In the result, the appeal for the AY 2018-19 filed by the appellant is partly allowed

ITA 1008/DEL/2023[2018-19]Status: DisposedITAT Delhi09 Jul 2024AY 2018-19

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasada.Yr. : 2018-19 Dks Shiksha Prasar Samiti, Vs. Acit, Circle 1(1)(1), Meerut Meerut 8, Panchsheel Colony, Uttar Pradesh Meerut, Uttar Pradesh-250004 (Pan: Aaatd7191H) (Appellant) (Respondent) Assessee By : Shri S.B. Gupta, Ca Department By : Shri Vivek Kumar Upadhyay, Sr. Dr.

For Appellant: Shri S.B. Gupta, CAFor Respondent: Shri Vivek Kumar Upadhyay, Sr. DR
Section 12ASection 143Section 143(1)Section 143(3)Section 156

Assessing Officer to follow the directions of the Ld. CIT(A), as aforesaid, and pass a fresh order, after giving adequate opportunity of being heard to the assessee. In the result, Asessee’s appeal is allowed for statistical purposes. 7. Order pronounced on 09/07/2024. (CHALLA NAGENDRA PRASAD) ACCOUNTANT MEMBER

Ketan Arvindbhai Patel, Sojitra vs. Income Tax Officer, Ward-2, Anand

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

ITA 269/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad08 Jul 2024AY 2016-17

Bench: Shri Ramit Kochar (Accountant Member)

For Appellant: Shri Kedar Vyas, A.RFor Respondent: Shri N.J. Vyas, Sr. D.R
Section 139(4)Section 139(5)Section 144Section 250

circumstances and in the interest of justice and natural justice, I am of the considered view that the assessee was not granted proper opportunity of being heard by both the assessing officer as well as CIT(A) and the orders were passed in haste, and clearly it is visible that

Chinmaya Seva Trust, Nagpur vs. CIT (Exemption), CIT (E), Income Tax Office, Pmt Building, Shankar Seth Road, Pune

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

ITA 347/NAG/2023[2023-24]Status: DisposedITAT Nagpur08 Jul 2024AY 2023-24

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Naresh Jakhotia, CAFor Respondent: Shri Rajeev Benjwal, CIT.Dr
Section 80GSection 80G(5)

approval granted under section 80G(5) of the Income Tax Act, 1961 should not be cancelled. The assessee was also given opportunity of being heard vide the said notice. The assessee was specifically informed that in the event of failure to comply by the due date, the application shall

M/S Seth Jamunadas Mundhra Seva Sansthan, Kolkata vs. ITO, Ward-1(3) -Exemption, Kolkata

The appeal of the assessee is allowed for statistical purposes

ITA 733/KOL/2024[2021-22]Status: DisposedITAT Kolkata08 Jul 2024AY 2021-22

Bench: Shri Sonjoy Sarma & Shri Sanjay Awasthii.T.A. No.733/Kol/2024 Assessment Year: 2021-22 M/S Seth Jamunadas Mundhra Seva Sansthan........................……….……Appellant 7Th Floor, 55, Ezra Street, Near Tea Board, Kolkata -1. [Pan: Aabts5460R] Vs. Ito, Ward-1(3), Kolkata.............…..….…..….........……........……...…..…..Respondent Appearances By: Shri Sunil Surana, Fca, Appeared On Behalf Of The Appellant. Shri Sanjay Paul, Addl. Cit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 02, 2024 Date Of Pronouncing The Order : July 08, 2024 Order Per Sonjoy Sarma: The Present Appeal Is Filed By The Assessee Pertaining To Assessment Year 2021-22 Is Directed Against The Order Passed By National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Dated 31.01.2024 U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Assessee Is In Appeal Before This Tribunal Raising The Following Grounds Of Appeal, Which Are As Under:

Section 11Section 12ASection 143(1)Section 154Section 250

aside and remanded back to the ld. CIT(A) with a direction to reconsider the issue afresh after affording reasonable opportunity of being heard to the assessee. 7. On the other hand, the ld. DR supported the order of the lower authorities below. 7. We, after considering the rival submission ... simply rejecting the appeal of the assessee. We, therefore, direct the ld. CIT(A) to re-examine the issue after affording reasonable opportunity of being heard to the assessee. 3 I.T.A. No.733/Kol/2024 Assessment Year: 2021-22 M/s Seth Jamunadas Mundhra Seva Sansthan 8. In terms of the above, the appeal

Uttaran, Kolkata vs. CIT(Exemption), Kolkata

In the result, all the three appeals of the different assessee(s) are allowed for statistical purposes

ITA 716/KOL/2024[00]Status: DisposedITAT Kolkata08 Jul 2024

Bench: Dr. Manish Boradshri Pradip Kumar Choubey

Section 80G(5)Section 80G(5)(iii)

grant the approval u/s 80G(5)(iii) of the Act if the assessee(s) is otherwise found eligible. Needless to mention the proper opportunity of being heard should be provided to the Assessee’s. 9. In the result, all the three appeals of the different assessee(s) are allowed

Kolkata Swasthya Sankalp, Kolkata vs. CIT(Exemption), Kolkata

In the result, all the three appeals of the different assessee(s) are allowed for statistical purposes

ITA 707/KOL/2024[00]Status: DisposedITAT Kolkata08 Jul 2024

Bench: Dr. Manish Boradshri Pradip Kumar Choubey

Section 80G(5)Section 80G(5)(iii)

grant the approval u/s 80G(5)(iii) of the Act if the assessee(s) is otherwise found eligible. Needless to mention the proper opportunity of being heard should be provided to the Assessee’s. 9. In the result, all the three appeals of the different assessee(s) are allowed

Children'S Little Threatre, Kolkata vs. CIT(Exemption, Kolkata

In the result, all the three appeals of the different assessee(s) are allowed for statistical purposes

ITA 350/KOL/2024[00]Status: DisposedITAT Kolkata08 Jul 2024

Bench: Dr. Manish Boradshri Pradip Kumar Choubey

Section 80G(5)Section 80G(5)(iii)

grant the approval u/s 80G(5)(iii) of the Act if the assessee(s) is otherwise found eligible. Needless to mention the proper opportunity of being heard should be provided to the Assessee’s. 9. In the result, all the three appeals of the different assessee(s) are allowed

Alosha Marketing Pvt. Ltd., Kolkata vs. ACIT, Cir. 4(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 313/KOL/2024[2013-14]Status: DisposedITAT Kolkata08 Jul 2024AY 2013-14

Bench: Shri Rajpal Yadav, Vice-(Kz) & Dr. Manish Boradi.T.A. No. 313/Kol/2024 Assessment Year: 2013-2014 Alosha Marketing Pvt. Ltd.,……………..………Appellant 62A, Hazra Road, Kolkata-700019 [Pan:Aacca1930G] -Vs.- Assistant Commissioner Of Income Tax,.…Respondent Circle-4(1), Kolkata, Aayakar Bhawan, P-7, Chowringhee Square, Kolkata-700069 Appearances By: Shri N.S. Saini, A.R. & Priyanka Salarpuria, A.R., Appeared On Behalf Of The Assessee Shri Manas Mondal, Addl. Cit, Sr. D.R., Appeared On Behalf Of The Revenue Date Of Concluding The Hearing : April 30, 2024 Date Of Pronouncing The Order : July 08, 2024 O R D E R

Section 143(2)Section 147Section 148Section 68

Phlox Tradecom Pvt Ltd during the A.Y. 2013-14 will be treated as your undisclosed income, without giving any further opportunity of being heard to you.' Investigation of department has made detail enquiry in the case. It was found that all the abovementioned companies are involved in providing accommodation entry ... bank account during the financial year 2012-13 relevant to assessment year 2013-14 from above mentioned companies. Even though opportunity of being heard was provided to the assessee but the assessee company failed to discharge the onus to prove the transactions as being genuine and failed to discharge

Mani Dinesh, Namakkal vs. ITO Ward 2, Tiruchengode

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

ITA 814/CHNY/2024[2011-12]Status: DisposedITAT Chennai08 Jul 2024AY 2011-12

Bench: Shri Mahavir Singh, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 814/Chny/2024 िनधा"रणवष" / Assessment Year: 2011-12 Income Tax Officer, Mani Dinesh V. Ward -2, No.3/740, Ethirmedu Tiruchengode. Thattankuttai, Komarapalayam, Namakkal – 638 183. [Pan: Awspd-5423-G] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ"क"ओरसे/Appellant By : Shri. S. Sridhar, Advocate (Erode) (Virtual) ""यथ"क"ओरसे/Respondent By: Shri. G. Suresh, Jcit सुनवाईकीतारीख/Date Of Hearing : 08.07.2024 घोषणाकीतारीख/Date Of Pronouncement : 08.07.2024 आदेश /O R D E R Per S. R. Raghunatha:

For Appellant: Shri. S. Sridhar, Advocate (Erode) (virtual)For Respondent: Shri. G. Suresh, JCIT
Section 143(2)Section 143(3)Section 148Section 44ASection 69Section 69A

assessee and the AO completed the assessment by passing an order U/s.143(3) r.w.s. 147 of the Act on 26.112019, after providing proper opportunity of being heard, and made an addition of cash deposits made to the bank account of Rs.18,00,000/- U/s.69A of the Act, as unexplained money

Swabhiman, Dantaraamgarh vs. CIT(Exemption), Jaipur

In the result, appeal of the assessee is dismissed as withdrawn

ITA 612/JPR/2024[2023-24]Status: DisposedITAT Jaipur08 Jul 2024AY 2023-24

Bench: Dr.S.Seethalakshmi & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.612/Jpr/2024 िनधा"रण वष" / Assessment Year : 2023-24 Swabhiman, The Commissioner Of Dhabayli Kothi, Danta, V Income Tehsil-Dantaramgarh, Sikar, S Tax(Exemption), Rajasthan – 332702. Jaipur. Pan: Aalas5226J Appellant / Assessee Respondent / Revenue Assessee By Shri Sharwan Kumar Gupta – Advocate & Shri Ashok Kumar Gupta, Adv. Revenue By Shri Arvind Kumar – Cit(Dr) Date Of Hearing 08/07/2024 Date Of Pronouncement 08/07/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Jaipur Dated 30.03.2024 Passed Under Section 80G Of The Income Tax Act, 1961 Rejecting The Assessee’S Application Filed In Form No.10Ab For Swabhiman, Dantaraamgarh [A]

Section 80GSection 80G(5)

Gro1. The Impugned order u/s 80G(5) of the Act dated 30.03.2024 is bad in law and on facts, without providing adequate & reasonable opportunity of being heard, being without jurisdiction and for various other reasons and hence the same may kindly be quashed.und 2. The Ld. CIT(E) erred

Shri. Rafeeq Ismailsab Bairakdar, Mudhol vs. Income Tax Officer, Ward-1, Tps, Bagalkote

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

ITA 612/BANG/2024[2018-19]Status: DisposedITAT Bangalore08 Jul 2024AY 2018-19

Bench: Shri Chandra Poojari & Shri Keshav Dubeyrafeeq Ismailsab Bairakdar The Income Tax Officer Cts Yadawad Cross Ward 1 & Tps Lokapur Mudhol Vs. Aayakar Bhavan Mudhol 587313 Sector No. 24, Navanagar Pan – Ayspb5817A Bagalkot 587102 (Appellant) (Respondent) Assessee By: Shri Saidappa B. Gadadi, Ca Revenue By: Shri Guru Kumar S., Addl Cit-Dr Date Of Hearing: 28.05.2024 Date Of Pronouncement: 08.06.2024 O R D E R Per: Keshav Dubey, J.M. This Appeal At The Instance Of The Assessee Is Directed Against Din & Order No. Itba/Nfac/S/250/2023-24/1060531591(1) Of The National Faceless Appeal Centre, Delhi (Cit(A)) Dated 06.02.2024 Under Section 250 Of The Income Tax Act, 1961 (The Act) For Assessment Year (Ay) 2018-19. 2. The Assessee Has Raised The Following Grounds Of Appeal: - “1. The Hon'Ble Cit (Appeals) Being A Quasi-Judicial Authority Has Failed Verify The Loan Taken From Shri Aslam I Bairkadar As In The Appellate Order The Learned Cit(A) Has Reiterated The Name Of Appellant Only It Shows That Order Has Been Passed In Hurry Burry Manner Without Going Into Detailed Verification & Simply Stated Assessee Has Submitted Only Icici Bank Account. 2. The Hon'Ble Cit(Appeals) Has Erred In Not Giving Reasonable Opportunity Of Being Heard While Confirming The Additions As Every Time The Learned Cit(A) Has Asked "In Support Of Your

For Appellant: Shri Saidappa B. Gadadi, CAFor Respondent: Shri Guru Kumar S., Addl CIT-DR
Section 133(6)Section 250Section 37Section 44ASection 68

verification and simply stated assessee has submitted only ICICI bank account. 2. The Hon'ble CIT(Appeals) has erred in not giving reasonable opportunity of being heard while confirming the additions as every time the learned CIT(A) has asked "in support of your 2 Rafeeq Ismailsab Bairakdar Grounds

Pukhraj Bhomaji Mutha, Mumbai vs. ITO-19(2)(5), Mumbai

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

ITA 2150/MUM/2024[2012-13]Status: DisposedITAT Mumbai08 Jul 2024AY 2012-13

Bench: Shri Pavan Kumar Gadale & Shri Omkareshwar Chidaravs. Ito -19(2)(5), Pukhraj Bhomaji Mutha, Piramal Chambers, 1605, Siddesh Darshan, Lalbaug, 10Th Khetwadi, Mumbai-400012. Mumbai – 400004. Pan/Gir No. Aacpm4077H (अपीलाथ"/Appellant) (""यथ"/Respondent)

Section 144Section 148

Officer have erred on facts and in law in passing the ex-parte assessment order and appellate order without giving proper and reasonable opportunity of being heard. 2. That the Id. Assessing Officer and ld. CIT (Appeal) have erred in making and confirming the addition made u/s.69

Darshan Lal Saraf Private Limited, Krishna Nagar, Delhi vs. Income Tax Officer Ward-7(2), Delhi

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

ITA 878/DEL/2024[2017-18]Status: DisposedITAT Delhi08 Jul 2024AY 2017-18

Bench: Shri Kul Bharat & Shri Brajesh Kumar Singh[Assessment Year 2017-18]

Section 139ASection 145(3)Section 68

file of the ld. CIT(A) for adjudication of the same afresh. The Ld. CIT(A) will also grant a reasonable opportunity of being heard before deciding the appeal of the assessee. The grounds of appeal are allowed for statistical purposes. 6. In the result, appeal of the assessee

Imw Care Foundation, Delhi vs. CIT(Exemption), Delhi

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

ITA 397/DEL/2024[2023-24]Status: DisposedITAT Delhi08 Jul 2024AY 2023-24

Bench: Shri G. S. Pannu & Ms. Madhumita Royi.T.A. Nos. 396 & 397/Del/2024 (Assessment Year : 2023-24) Imw Care Foundation Vs. Cit(Exemption) F. No.84, Sector-D, Delhi Pocket-6, Lig Kaveri Near, Vasant Kunj, New Delhi – 70 Pan: Aafci 3956 F .. (Respondent) (Appellant) Appellant By : Shri Priyansh Jain, C.A. Respondent By : Ms. Rishpal Bedi, Cit-D.R. Date Of Hearing 02.07.2024 Date Of Pronouncement 08.07.2024 O R D E R Per Ms. Madhumita Roy –:

For Appellant: Shri Priyansh Jain, C.AFor Respondent: Ms. Rishpal Bedi, CIT-D.R
Section 12ASection 80G(5)(iii)

Vaneeta Kumari dated 01.07.2024, duly notarized by the competitive authority. In that view of the matter, the Learned AR prays for a further opportunity of being heard in order to enable the ITA Nos.396 & 397/Del/2024 IMW Care Foundation vs. CIT(E) Asst.Year : 2023-24 3 - assessee to represent ... circumstance of the case, we in order to prevent the miscarriage of justice find it fit and proper to grant a further opportunity of being heard to the assessee by the Learned CIT(E) in order to enable the assessee to represent its case for grant of final registration under

Imw Care Foundation, Delhi vs. CIT(Exemption), Delhi

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

ITA 396/DEL/2024[2023-24]Status: DisposedITAT Delhi08 Jul 2024AY 2023-24

Bench: Shri G. S. Pannu & Ms. Madhumita Royi.T.A. Nos. 396 & 397/Del/2024 (Assessment Year : 2023-24) Imw Care Foundation Vs. Cit(Exemption) F. No.84, Sector-D, Delhi Pocket-6, Lig Kaveri Near, Vasant Kunj, New Delhi – 70 Pan: Aafci 3956 F .. (Respondent) (Appellant) Appellant By : Shri Priyansh Jain, C.A. Respondent By : Ms. Rishpal Bedi, Cit-D.R. Date Of Hearing 02.07.2024 Date Of Pronouncement 08.07.2024 O R D E R Per Ms. Madhumita Roy –:

For Appellant: Shri Priyansh Jain, C.AFor Respondent: Ms. Rishpal Bedi, CIT-D.R
Section 12ASection 80G(5)(iii)

Vaneeta Kumari dated 01.07.2024, duly notarized by the competitive authority. In that view of the matter, the Learned AR prays for a further opportunity of being heard in order to enable the ITA Nos.396 & 397/Del/2024 IMW Care Foundation vs. CIT(E) Asst.Year : 2023-24 3 - assessee to represent ... circumstance of the case, we in order to prevent the miscarriage of justice find it fit and proper to grant a further opportunity of being heard to the assessee by the Learned CIT(E) in order to enable the assessee to represent its case for grant of final registration under

Insat Exports Pvt. Ltd., Delhi vs. DCIT, Circle-10(1), Delhi

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

ITA 3730/DEL/2023[2018-19]Status: DisposedITAT Delhi08 Jul 2024AY 2018-19

Bench: Shri G. S. Pannu & Ms. Madhumita Royi.T.A. No. 3730/Del/2023 (Assessment Year: 2018-19) Insat Exports Pvt. Ltd. Vs. Dcit C/O C.S. Anand, Advocate Circle – 10(1) 104 Pankaj Tower, New Delhi 10 Lsc, Savita Vihar, Delhi – 110 092 Pan: Aaaci 2250 D (Appellant) .. (Respondent)

For Appellant: Shri C. S. Anand, AdvFor Respondent: Shri T. James Singson, CIT-D.R
Section 115BSection 142(1)Section 143(3)Section 250Section 69

reconcile the difference in purchase as per ITR/Books and as per CBEC data. The Learned AO is further directed to grant an opportunity of being heard to the assessee and to pass a reasoned order strictly in accordance with law. 8. In the result, appeal of the assessee is allowed

DCIT, Exemption Circle, Ghaziabad, Uttar Pradesh vs. Jhansi Development Authority, Jhansi, Uttar Pradesh

ITA 2693/DEL/2023[2017-18]Status: DisposedITAT Delhi08 Jul 2024AY 2017-18

Bench: Shri G. S. Pannu & Ms. Madhumita Royi.T.A. Nos. 2689, 2690, 2691, 2692 & 2693 /Del/2023 (Assessment Years : 2014-15, 2015-16, 2015-16, 2016-17 & 2017-18) Dy. Commissioner Of Vs. Jhansi Development Income Tax, Exemption- Authority, Circle, Ghaziabad, Uttar Commissionery Campus, Pradesh Jhansi Railway Station S.O. Jhansi - Uttar Pradesh Pan: Aaalj 0068 K (Appellant) .. (Respondent)

For Appellant: Shri G. C. Srivastava, Adv. &For Respondent: Ms. Rishpal Bedi, CIT-D.R
Section 11Section 143(3)Section 2(15)Section 250(6)

light of the observations made by Hon’ble Apex Court as narrated hereinabove. The Learned AO is further directed to grant an opportunity of being heard to the assessee and to consider the evidence on record or any other evidence which the assessee may choose to file at the time

DCIT, Exemption Circle, Ghaziabad, Uttar Pradesh vs. Jhansi Development Authority, Jhansi, Uttar Pradesh

ITA 2692/DEL/2023[2016-17]Status: DisposedITAT Delhi08 Jul 2024AY 2016-17

Bench: Shri G. S. Pannu & Ms. Madhumita Royi.T.A. Nos. 2689, 2690, 2691, 2692 & 2693 /Del/2023 (Assessment Years : 2014-15, 2015-16, 2015-16, 2016-17 & 2017-18) Dy. Commissioner Of Vs. Jhansi Development Income Tax, Exemption- Authority, Circle, Ghaziabad, Uttar Commissionery Campus, Pradesh Jhansi Railway Station S.O. Jhansi - Uttar Pradesh Pan: Aaalj 0068 K (Appellant) .. (Respondent)

For Appellant: Shri G. C. Srivastava, Adv. &For Respondent: Ms. Rishpal Bedi, CIT-D.R
Section 11Section 143(3)Section 2(15)Section 250(6)

light of the observations made by Hon’ble Apex Court as narrated hereinabove. The Learned AO is further directed to grant an opportunity of being heard to the assessee and to consider the evidence on record or any other evidence which the assessee may choose to file at the time