“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

M/S. Birmani Charitable Foundation, Nashik vs. Commissioner of Income Tax (Exemption), Pune

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

ITA 113/PUN/2024[--]Status: DisposedITAT Pune28 Mar 2024

Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.113/Pun/2024 िनधा"रण वष" / Assessment Year : N.A. M/S.Birmani Charitable The Commissioner Of Foundation, V Income Tax(Exemption), H 227, Deepak Mahal, Lam S Pune. Road, Deolali Camp, Dist.Nashik – 422401. Pan: Aaicb8213B Appellant/ Assessee Respondent /Revenue Assessee By Shri Sanket M Joshi – Ar Revenue By Shri Keyur Patel – Cit(Dr) Date Of Hearing 28/03/2024 Date Of Pronouncement 28/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Exemption), Pune Dated 03.11.2023 Passed Under Section 80G Of The Income Tax Act, 1961 Rejecting The Assessee’S Application Filed In Form No.10Ab For Approval Under Section 80G(5) Of The Act. The Assessee Has Raised The Following Grounds Of Appeal : M/S.Birmani Charitable Foundation [A]

Section 10Section 12ASection 80GSection 80G(5)

case referred to in sub-clause (B) of clause (iv) of the first proviso, rejecting such application, after affording it a reasonable opportunity of being heard;] (iii) ……. 5. The Commissioner of Income Tax (Exemption), Pune in the case of the Assessee held that the Activities of the Assessee had commenced

Srinivasa Rao Inuganti, Mylavaram vs. Income Tax Officer, Ward-3(1), Vijayawada

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

ITA 28/VIZ/2024[2017-18]Status: DisposedITAT Visakhapatnam28 Mar 2024AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Hon’Bleआयकर अपील सं./I.T.A.No.28/Viz/2024 (ननधधारण वर्ा / Assessment Year : 2017-18) Srinivasa Rao Inuganti Vs. Income Tax Officer Sy.No.537/5, S.V.S.Nager Ward-3(1) Mylavaram Vijayawada Ntr District [Pan : Abdpi5709C] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri Siva Ram Kumar, ARFor Respondent: Dr.Aparna Villuri, DR

Section 143(2)Section 143(3)Section 271ASection 57Section 69A

email address of the said AR were not served. The Ld. AR therefore pleaded for reconsideration of his appeal and afford an opportunity of being heard before the Ld.CIT(A) in view of the aforesaid exceptional circumstances. 6. Per contra, the Ld.DR relied on the order of the Ld.CIT ... submitted a copy of death certificate of the Ld.AR issued at Australia and pleaded for reconsideration of the appeal by granting one more opportunity of being heard before the Ld.CIT(A). In view of the aforesaid facts and circumstances of the case and keeping in view the principles of natural

Ganta Venkata Nanda Kishore, Tanuku vs. Income Tax Officer, Ward-1, Tanuku

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

ITA 274/VIZ/2023[2013-14]Status: DisposedITAT Visakhapatnam28 Mar 2024AY 2013-14

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.274/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2013-14) Venkata Nanda Kishore Ganta Vs. Income Tax Officer D.No.5-1, Near Satram Ward-1 Pydiparru Post Tanuku Tanuku, West Godavari [Pan : Anbpg4942R] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Dr.Aparna Villuri, DR

Section 142(1)Section 143(2)Section 147Section 148Section 69A

matter back to the file of the AO to verify the cash deposits as directed by the Ld.CIT(A) after giving an opportunity of being heard to the assessee and pass order accordingly. The assessee is also directed to adhere to the notices issued and cooperate with the revenue authorities

Compucom Software Limited Employees Welfare Trust, Jaipur vs. ITO, Exemption, Ward-1, Jaipur

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

ITA 168/JPR/2024[2016-17]Status: DisposedITAT Jaipur28 Mar 2024AY 2016-17

Bench: SHRI MANISH BORAD (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Respondent: Smt. Monisha Choudhary (Addl.CIT) a

Section 143(1)(a)

appeal before the ld. CIT(A) and accordingly, direct the ld. CIT(A) to adjudicate the issue on merit for which necessary opportunity of being heard shall be provided. The assessee is also directed to appear before the ld. CIT(A) on the given date of hearing and shall

Pawan Gupta, Jaipur vs. Assistant Commissioner Circle-2, Jaipur

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

ITA 167/JPR/2024[2017-2018]Status: DisposedITAT Jaipur28 Mar 2024AY 2017-2018

Bench: SHRI MANISH BORAD (Accountant Member), DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Miss Shivangi Mewal (Adv.)For Respondent: Smt. Monisha Choudhary (Addl.CIT) a

Section 143(3)

adjudication of the issues on merit to decide in accordance with law . Needless to mention that assessee shall be provided reasonable opportunity of being heard. 7. In the result, the appeal filed by the assessee is allowed for statistical purposes. Order pronounced in the open Court on 28/03/2024

Heritage Sagar Enterprises, Mumbai vs. Joint CIT Rang 22 (1), Mumbai

ITA 3809/MUM/2023[2011-12]Status: DisposedITAT Mumbai28 Mar 2024AY 2011-12

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Bharat KanabarFor Respondent: Shri P.D. Chougule

Section 143(3)Section 145Section 43BSection 69C

aforesaid, we deem it appropriate to remand this issue back to the file of the CIT(A) for adjudication after granting Appellant reasonable opportunity of being heard. The Appellant is directed to be diligent and file all documents/details before the CIT(A) in support of its contentions/submission. It is clarified ... issues raised in Ground No. 2, 3, & 4 back to the file of the CIT(A) for adjudication after granting appellant reasonable opportunity of being heard. The Appellant is directed to be diligent and file all documents/details before the CIT(A) in support of its contentions/submission. In terms

Hayward Synthetics P Ltd, Mumbai vs. DCIT Circle 2 (1) (1), Mumbai

In the result, present appeal is allowed for statistical purposes

ITA 3644/MUM/2023[2015-16]Status: DisposedITAT Mumbai28 Mar 2024AY 2015-16

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Dr. K.ShivaramFor Respondent: Shri P.D. Chougule

Section 143(3)Section 250

same afresh taking into consideration submissions dated 09/03/2021 and 23/09/2022 filed by the Appellant and after granting the Appellant reasonable opportunity of being heard. The Appellant is directed to file all the relevant documents/details in support of its claim before the CIT(A). The CIT(A) is directed to take

Idemia Syscom India Private Limited, Noida vs. CIT(Tp), Delhi-2, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 647/DEL/2024[2020-21]Status: DisposedITAT Delhi28 Mar 2024AY 2020-21

Bench: Shri Saktijit Dey & Shri N.K. Billaiya

For Appellant: Shri M.S. Syali, Sr. AdvFor Respondent: Shri Rajesh Kumar, CIT- DR

Section 263Section 92C

grossly violates applicable rules of natural justice in as much as inter alia: (a) not providing an opportunity of being heard in person, (b) passing the impugned order in haste (c) not allowing the appellant adequate time to prepare and represent. has thereby violated the settled principles. 4. That ... erroneous in so far as it is prejudicial to the interests of the revenue, he may, after giving the assessee 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

Defsys Solutions Pvt. Ltd., New Delhi vs. ACIT, Central Circle-15, New Delhi

In the result the appeal of the assessee in ITA No

ITA 758/DEL/2023[2019-20]Status: DisposedITAT Delhi28 Mar 2024AY 2019-20

Bench: Shri N.K. Billaiya & Ms Astha Chandra

For Appellant: Shri Ajay Wadhwa, AdvFor Respondent: Shri Rajesh Kumar, CIT-DR

Section 115BSection 139(1)Section 144CSection 153ASection 156Section 270ASection 271ASection 274Section 36(1)(va)Section 37(1)

with the directions, complete, notwithstanding anything to the contrary contained in section 153 51a[or section 153B], the assessment without providing any further opportunity of being heard to the assessee, within one month from the end of the month in which such direction is received.” 17. In light

ADIT Infrapower & Multitrading Pvt Ltd, New Delhi vs. ITO Ward - 1(3), Gurgaon

The appeal is dismissed

ITA 903/DEL/2020[2014-15]Status: DisposedITAT Delhi28 Mar 2024AY 2014-15

Bench: Shri G.S. Pannu, Hon’Ble & Shri Anubhav Sharmaassessment Year: 2014-15 Adit Infrapower & Multitrading Vs Ito, Pvt. Ltd., Ward-1(3), Da-08, 2Nd Floor, Vikas Marg, Gurgaon. Shakarpur, New Delhi. Pan: Aahca5582H (Appellant) (Respondent) Assessee By : None Revenue By : Shri Aasish Mohanty, Cit-Dr Date Of Hearing : 30.11.2023 Date Of Pronouncement : 28.02.2024 Order Per Anubhav Sharma, Jm:

For Appellant: NoneFor Respondent: Shri Aasish Mohanty, CIT-DR

Section 133(6)Section 143(3)Section 263Section 56Section 56(2)(viib)

directed to frame the assessment order afresh w.r.t. the applicability of section 56(viib)/68 of the Act after affording the assessee an opportunity of being heard. 2 3. As per the above directions of the ld. PCIT, the AO vide his order dated 10th December, 2019, passed a fresh ... case, the Ld. AO has erred in law in invoking jurisdiction while giving effect to the order of section 263 without giving opportunity of being heard to the assessee as assessee has a jurisdiction of Gurgaon, order u/s 143(3) passed by Ld. AO, Ward 1(1), Gurgaon, order

The Anigandlapadu Pacs Ltd, Krishna Dist vs. Income Tax Officer, Ward(1)1 Vijayawada, Vijayawada

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

ITA 300/VIZ/2023[2020-21]Status: DisposedITAT Visakhapatnam27 Mar 2024AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.300/Viz/2023 (ननधधारण वर्ा / Assessment Year : 2020-21) The Anigandlapadu Pacs Ltd. Vs. Income Tax Officer 10-1, Anigandlapadu Village Ward-1(1) Penuganchiprolu Post Vijayawada Penuganchiprolu Mandal Krishna Dist. [Pan : Aacat7983Q] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent)

For Appellant: Shri ASRSS Sivaprasad, ARFor Respondent: Dr.Aparna Villuri, DR

Section 142(1)Section 147Section 56Section 80P

Business or Profession” and the assessee is eligible for claiming deduction u/s 80P of the Act. The assessee has pleaded for affording an opportunity of being heard before the Ld.CIT(A) to substantiate assessee’s case with credible material evidences available. In view of the foregoing facts and circumstances ... principles of natural justice, we are inclined to remit the matter back to the file of the Ld.CIT(A) for giving an opportunity of being heard to the assessee and pass order after examination of the material evidences furnished by the assessee society. The assessee is also directed to adhere

Presidency Finance Limited, Chennai vs. DCIT, Corporate Circle-5(2), Chennai

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

ITA 1477/CHNY/2023[2017-18]Status: DisposedITAT Chennai27 Mar 2024AY 2017-18

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.1477/Chny/2023 िनधा"रण वष"/Assessment Year: 2017-18 Presidency Finance Limited, Vs. The Deputy Commissioner Of 24/12, 3Rd Floor, Raghaviah Road, Income Tax, T. Nagar, Chennai 600 017. Corporate Circle 5(2), [Pan:Aaccp4841R] Chennai. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Y. Sridhar, F.C.A ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 25.03.2024 घोषणा की तारीख /Date Of Pronouncement : 27.03.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, Dated 17.10.2023 Relevant To The Assessment Year 2017-18. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2017-18 On 11.10.2017 Admitting A Total Income Of ₹.80,45,362/- Under Normal Provisions & Book Profit Of ₹.44,41,615/-. The Case Was Selected For Scrutiny Through Cass & 2

For Appellant: Shri Y. Sridhar, F.C.A ""For Respondent: Shri D. Hema Bhupal, JCIT

Section 142(1)Section 143(2)Section 68

further submission that without affording adequate opportunities, the Assessing Officer has hurriedly concluded the assessment and prayed for affording one more opportunity of being heard to substantiate the claim of the assessee. So far as restriction of expenses at 30%, the ld. counsel has submitted that the assessee has complete ... that the assessee has complete details towards expenses incurred and the entire expenses have to be allowed and prayed for affording one more opportunity of being heard to the assessee. 9. In view of the above facts and circumstances, we are of the opinion that to meet the ends

Thikariya Gram Sewa Sahkari Samiti Ltd, Thikariya vs. AO Cpcito Ward Sikar, Sikar

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

ITA 772/JPR/2023[2018-19]Status: DisposedITAT Jaipur27 Mar 2024AY 2018-19

For Appellant: Shri Shrawan Kumar Gupta AdvocateFor Respondent: Mrs. Monisha Choudhary, Addl. CIT

Section 143(1)Section 234ASection 80P

facts of the case in passing the Ex parte order and confirming the order of the ld. AO without providing adequate and reasonable opportunity of being heard and not considering the material on record in the gross breach of natural justice. Hence the same entire addition may kindly be deleted ... facts of the case in passing the Ex parte order and confirming the order of the ld. AO without providing adequate and reasonable opportunity of being heard and not considering the material on record in the gross breach of natural justice. Hence the same entire addition may kindly be deleted

Executors of the Will of Late Smt. Gaindibai Barjatya, Mumbai vs. Jurisdictional Officer, Mumbai

ITA 1299/MUM/2024[2020-21]Status: DisposedITAT Mumbai27 Mar 2024AY 2020-21

Bench: Shri Vikas Awasthy & Shri Amarjit Singh

For Appellant: Respondent byFor Respondent: Date of Hearing

Section 115Section 115JSection 143(3)

NFAC for A.Y. 2016-17. The assessee has raised the following grounds before us: “Ground No. 1: No reasonable opportunity of being heard granted: 1. On the facts and in the circumstances of the case and in law, the Appellant was not provided with sufficient and reasonable opportunity of being

Harveer Singh, Ghaziabad vs. Income Tax Officer Ward 2(1)(3), Ghaziabad

In the result, the appeal of the assessee in ITA No

ITA 289/DEL/2024[2012-2013]Status: DisposedITAT Delhi27 Mar 2024AY 2012-2013

Bench: Shri N.K. Billaiya

For Appellant: Shri Sumit Gupta, CAFor Respondent: Shri Om Prakash, Sr. DR

deem it fit to restore the appeal to the file of the NFAC/CIT(A) to be decided afresh after affording reasonable and adequate opportunity of being heard to the assessee. 6. In the result, the appeal of the assessee in ITA No. 289/DEL/2024 is allowed for statistical purposes. The order

Motherson Sumi Systems Limited, New Delhi vs. DCIT, New Delhi

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

ITA 2054/DEL/2015[2010-11]Status: DisposedITAT Delhi27 Mar 2024AY 2010-11

Bench: Shri Shamim Yahya & Ms. Astha Chandraasstt. Year: 2010-11

For Appellant: Shri K.M. Gupta, AdvocateFor Respondent: Shri Anuj Garg, Sr. DR

Section 108(4)Section 10BSection 10B(1)Section 143(3)Section 144CSection 234BSection 271(1)(e)Section 92D

learned TPO/Assessing Officer to decide the issue afresh in view of the above findings of the ITAT in the cited cases after affording opportunity of being heard to the assessee. The ground Nos. 3, 4 and 5 are accordingly allowed for statistical purposes.” 17. We have also perused the order

Govind Milk and Milk Products Pvt. Ltd., Phaltan vs. Income Tax Officer, Ward-3, Satara

ITA 848/PUN/2023[2016-17]Status: DisposedITAT Pune26 Mar 2024AY 2016-17

Bench: Shri Partha Sarathi Chaudhury & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.848/Pun/2023 िनधा"रण वष" / Assessment Year : 2016-17 Govind Milk & Milk Products The Income Tax Pvt. Ltd., V Officer, Ward-3, Ganesh Sheri, Pune Pandharpur S Satara. Road, At Post Kolki, Phaltan, Satara, Maharashtra. Pan: Aaacg7588A Appellant/ Assessee Respondent /Revenue Assessee By None. Revenue By Shri R.Y.Balawade – Addl.Cit Date Of Hearing 13/03/2024 Date Of Pronouncement 26/03/2024 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 Dated 25.05.2023. The Assessee For A.Y.2019-20 Has Raised The Following Grounds Of Appeal : “1. The Ld Cit(A) Erred In Passing Her Order Ex-Parte Without Allowing Appellant Reasonable Opportunity Of Being Heard. 2. The Ld Cit(A) Erred In Upholding The Disallowance Of Rs.43,51,377/- Under Section 40(A)(Ia) Made By The Ld Ao Without Govind Milk & Milk Products Pvt. Ltd., [A]

Section 194A(3)(iii)Section 201(1)Section 246ASection 250Section 250(4)Section 250(6)Section 251Section 251(1)(a)Section 40

raised the following grounds of appeal : “1. The Ld CIT(A) erred in passing her order ex-parte without allowing appellant reasonable opportunity of being heard. 2. The Ld CIT(A) erred in upholding the disallowance of Rs.43,51,377/- under section 40(a)(ia) made

Diwakar Road Lines, Anantapur vs. Asst. Commissioner of Income Tax, Circle-1, Anantapur

In the result, appeal for the assessment year 2014-15 is treated as allowed for statistical purposes

ITA 74/HYD/2024[2016-17]Status: DisposedITAT Hyderabad26 Mar 2024AY 2016-17

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

For Appellant: Shri K.A. Sai Prasad, ARFor Respondent: Shri Shakeer Ahamed, DR

Section 66

Officer, which resulted in disposal of the matter, without documents and also ex parte disposal of the appeal. learned AR prayed for another opportunity of being heard before the learned Assessing Officer, so that all the material would be produced to get the matter disposed-of on merits. 17. Learned

Diwakar Road Lines, Anantapur vs. Asst. Commissioner of Income Tax, Circle-1, Anantapur

In the result, appeal for the assessment year 2014-15 is treated as allowed for statistical purposes

ITA 73/HYD/2024[2014-15]Status: DisposedITAT Hyderabad26 Mar 2024AY 2014-15

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

For Appellant: Shri K.A. Sai Prasad, ARFor Respondent: Shri Shakeer Ahamed, DR

Section 66

Diwakar Road Lines, Anantahapur vs. Asst. Commissioner of Income Tax, Circle-1, Anantapur

In the result, appeal for the assessment year 2014-15 is treated as allowed for statistical purposes

ITA 72/HYD/2024[2011-12]Status: DisposedITAT Hyderabad26 Mar 2024AY 2011-12

Bench: Shri Rama Kanta Panda & Shri K.Narasimha Chary

For Appellant: Shri K.A. Sai Prasad, ARFor Respondent: Shri Shakeer Ahamed, DR

Section 66