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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

The ITO, Ward-3(2)(5), Ahmedabad vs. Shree Shreyanshnath Developers, Ahmedabad

In the result, the appeal of the Revenue is allowed

ITA 3053/AHD/2015[2007-08]Status: DisposedITAT Ahmedabad07 Feb 2024AY 2007-08

Bench: Smt.Annapurna Gupta & Shri T.R. Senthil Kumarassessment Year :2007-08 Ito, Ward-3(2)(5) Shree Shreyansnath Developers Ahmedabad. Vs Block No.832, Binor Bungalows Ghuma Gam Tal. Daskroi, Ahmedabad. Pan : Aaxfs 3932 L

Section 250(6)Section 80Section 80I

Gujarat High Court, and then pass necessary orders as per law in the light of the above discussion, after providing reasonable opportunity of being heard to the assessee. 9. A perusal of the above would reveal that the ITAT ,taking note of the decision of the Hon’ble Gujarat High

A.P. Grameena Vikas Bank, Warangal vs. DCIT Circle 3(1), Hyderabad

In the result, appeal of the assessee is allowed in above terms

ITA 416/HYD/2023[2010-11]Status: DisposedITAT Hyderabad07 Feb 2024AY 2010-11

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

For Appellant: Shri Darshan Jakharia, ARFor Respondent: Shri Shakeer Ahamed, DR
Section 143(3)Section 154Section 254Section 36(1)(vii)Section 36(1)(viia)

No.51/Hyd/2015, remitted the issue back to the file of the learned Assessing Officer for deciding the issue afresh after giving due opportunity of being heard to the assessee. 4. Pursuant to the remand by the Co-ordinate Bench of the Tribunal, assessment was completed under section 143(3) read with

Subhamoy Ghosh., Kolkata vs. CIT(A), Itd, Kolkata

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

ITA 920/KOL/2023[2017-18]Status: DisposedITAT Kolkata07 Feb 2024AY 2017-18

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2017-18 Subhamoy Ghosh Cit(A), Nfac, Delhi 3B, Shakespeare Sarani, Kolkata- Vs. 700071, West Bengal (Pan: Acvpg9442M) (Appellant) (Respondent)

For Appellant: Shri Amit Maharia, ARFor Respondent: Shri B. K. Singh, JCIT, Sr. DR
Section 147Section 249(4)

speaking order after taking into consideration the submissions and explanations furnished by the assessee. Needless to say that assessee be given reasonable opportunity of being heard to 3 Subhamoy Ghosh, AY 2017-18 represent its case. Accordingly, appeal of the assessee is allowed for statistical purposes. 4. In the result

Vidyasagar Teacher Training College., Burdwan vs. ITO, WD-4(3), Burdwan.

Appeal of the assessee is allowed for statistical purposes

ITA 830/KOL/2023[2017-18]Status: DisposedITAT Kolkata07 Feb 2024AY 2017-18

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2017-18 Vidyasagar Teacher Training Income Tax Officer, Ward- College, 4(3), Burdwan Bhabanandapur, Vs. Godaannadakalna, Panchrakhi, Burdwan, West Bengal-713122. (Pan: Aaalv0338G) (Appellant) (Respondent)

For Appellant: Shri Miraj D. Shah, ARFor Respondent: Shri Subhro Das, Addl. CIT, Sr. DR
Section 143(3)

thus pleaded that matter may be restored back to the file of Ld. CIT(A) by affording reasonable opportunity of being heard to the assessee and to make all the required submissions and explanation in support of the grounds raised. 5. Ld. Sr. DR when confronted with these submissions ... pass a speaking order after considering the submissions and explanations furnished by the assessee. Needless to say that assessee be given reasonable opportunity of being heard. We also direct the assessee to be diligent and not to seek adjournment unless warranted by compelling reasons for expeditious disposal of the appeal

M/S. Eastern Polypack Pvt.Ltd., Kolkata vs. ITO, Ward-3(1), Kolkata.

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

ITA 1311/KOL/2023[2008-09]Status: DisposedITAT Kolkata07 Feb 2024AY 2008-09

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2008-09 Eastern Polypack Pvt. Ltd. Income Tax Officer, Ward- C/O Subash Agarwal & 3(1), Kolkata. Associates, Advocates, Siddha Vs. Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kolkata-700069. (Pan: Aabce5756B) (Appellant) (Respondent)

For Appellant: Shri Siddharth Agarwal, AdvocateFor Respondent: Shri Subhro Das, Addl. CIT, Sr. DR
Section 147Section 250(6)

grounds taken by the assessee at the first appellate stage by passing a speaking order. Needless to say that assessee be given reasonable opportunity of being heard to make any further submission it wants to make in support of its grounds of appeal. Accordingly, ground no. 1 taken

Abhishek Shaw, North 24 Parganas vs. ITO, Ward-50(1), Kolkata

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

ITA 1039/KOL/2023[2017-18]Status: DisposedITAT Kolkata07 Feb 2024AY 2017-18

Bench: Shri Sanjay Garg & Shri Girish Agrawalassessment Year: 2017-18

For Appellant: Shri Miraj D. Shah, ARFor Respondent: Shri Subhro Das, Addl. CIT, Sr. DR
Section 144

appeal before the Ld. CIT(A). While disposing the appeal of the assessee, Ld. CIT(A) observed that assessee did not avail several opportunities of being heard given to him. Owing to non-appearance of the assessee, Ld. CIT(A) held that assessee is not interested in prosecuting his appeal ... course of assessment proceedings. Ld. AO is directed to deal with the issue meritoriously by passing a speaking order after affording reasonable opportunity of being heard to the assessee. Needless to say that assessee be given reasonable opportunity of being heard to make his representation and submission. Accordingly, appeal

S.K. V Eductional Trust, Chennai vs. ITO, Exemptions Ward-3, Chennai

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

ITA 1375/CHNY/2023[-]Status: DisposedITAT Chennai07 Feb 2024

Bench: Shri V. Durga Rao & Shri Manjunatha, G.आयकर अपील सं./I.T.A. No.1375/Chny/2023 S.K.V. Educational Trust, Vs. The Income Tax Officer, No. 21A, Nambikkai Arudhra Street, Exemptions Ward-3, T S Krishna Nagar, Mogappair, Chennai. Chennai 600 037. [Pan:Aazts7120G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Baskar, Advocate & Shri P.M. Kathir, Advocate ""थ" की ओर से/Respondent By : Shri Nilay Baran Som, Cit सुनवाई की तारीख/ Date Of Hearing : 01.02.2024 घोषणा की तारीख /Date Of Pronouncement : 07.02.2024 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 (Exemptions), Chennai, Dated 24.11.2022. 2. The Appeal Filed By The Assessee Is Delayed By 309 Days In Filing The Appeal, For Which, The Assessee Has Filed Detailed Petition For Condonation Of The Delay In The Form Of An Affidavit. By Referring To The Above Affidavit, The Ld. Counsel For The Assessee Has Submitted That There

For Appellant: Shri G. Baskar, Advocate &For Respondent: Shri Nilay Baran Som, CIT
Section 12ASection 12A(1)(ac)

other hand, the ld. DR fairly conceded that the assessee may be afforded one more opportunity of being heard. 3 I.T.A. No.1375/Chny/23 6. We have heard both the sides, perused the materials available on record and gone through the order passed by the ld. CIT(E) including paper book filed ... remit the matter back to the file of the ld. CIT(E) with a direction to afford reasonable opportunity of being heard to the assessee and decide grant of registration under section 12AB of the Act in accordance with law after considering the details as may be filed

Saravarakhan D Inamadar, Bagalkot vs. Income Tax Officer, Ward-2, Bagalkot

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

ITA 50/BANG/2024[2012-13]Status: DisposedITAT Bangalore07 Feb 2024AY 2012-13

Bench: Shri George George K & Shri Chandra Poojarind Shri Laxmi Prasad Sahuassessment Year : 2012-13 Shri. Saravarakhan D Inamadar, Vs. Ito, 750, Behind Kannada School, Ward – 2, Terdal Tal : Jamkhandi, Bagalkot. Dist: Bagalkot – 587 315. Pan : Acgpi 9415 F Appellant Respondent Assessee By : Shri. Ashok Mudnur, Ca Revenue By : Shri. Ganesh R Ghale, Standing Counsel For Revenue. Date Of Hearing : 07.02.2024 Date Of Pronouncement : 07.02.2024

For Appellant: Shri. Ashok Mudnur, CAFor Respondent: Shri. Ganesh R Ghale, Standing Counsel for Revenue
Section 144Section 250

deem it appropriate to remit the issue raised on merits to the files of the AO. The AO is directed to afford reasonable opportunity of being heard to the assessee. The assessee is directed to co-operate with the Revenue and not to seek unnecessary adjournments. With the aforesaid observations

Ntt Global Data Centers & Cloud Infrastructure India Private Limited (Erstwhile Netmagic It Services Private Limited), Mumbai vs. DCIT-10 (3)(1), Mumbai

In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

ITA 2784/MUM/2023[2015-16]Status: DisposedITAT Mumbai07 Feb 2024AY 2015-16

Bench: Shri Aby T Varkey, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blentt Global Data Centers & Cloud V. National E-Assessment Centre Infrastructure India Private Limited {Now Known As National {Erstwhile Netmagic It Services Faceless Appeal Centre} Private Limited} Delhi 7Th Floor, Hiranandani Business Park Sakinaka S.O., Mumbai - 400072 Pan: Aaccn2366D (Appellant) (Respondent) Assessee Represented By : Shri Vijay Mehta, Shri Arpit Doshi & Ms. Payal Mehta Department Represented By : Shri S. Srinivasu

Section 37(1)

Assessing Officer with a direction to verify the same as per law. It is needless to say that assessee may be given proper opportunity of being heard. Accordingly, Ground No. 2 raised by the assessee is allowed for statistical purpose. Page No. 22 NTT Global Data Centers & Cloud Infrastructure India ... records submitted by the assessee on merit and as per law. It is needless to say that assessee may be given a proper opportunity of being heard. In the result the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose. 23. In the result

National Securities Depository Limited, Mumbai vs. PCIT-8, Mumbai

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

ITA 1918/MUM/2023[2018-19]Status: DisposedITAT Mumbai07 Feb 2024AY 2018-19

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blenational Securities Depository Limited V. Pr.Cit-8 4Th Floor, A-Wing Room No. 611, 6Th Floor Trade World, Kamala Mills Compound Aayakar Bhavan, M.K. Road Senapati Bapat Marg, Lower Parel Mumbai - 400020 Mumbai - 400013 Pan: Aadcn9802F (Appellant) (Respondent) Assessee Represented By : Shri Percy Pardiwala & Shri Jeet Kamdae Department Represented By : Shri S. Srinivasu

Section 143(3)Section 14ASection 263Section 43B

order passed by the Assessing Officer is hereby set aside with the Page No. 4 National Securities Depository Limited direction to allow an opportunity of being heard to the assessee and thereafter pass the order in accordance with law after due verification. 8. Aggrieved with the above order assessee

Castrol India Ltd, Mumbai vs. NFAC, Delhi

In the result, the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose

ITA 2433/MUM/2022[2018-19]Status: DisposedITAT Mumbai07 Feb 2024AY 2018-19

Bench: Shri Vikas Awasthy, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blecastrol India Limited V. National Faceless Appeal Centre Technopolis Knowledge Park Delhi Mahakali Caves Road Chakala, Andheri (E) Mumbai – 400093 Pan: Aaacc4481E (Appellant) (Respondent) Assessee Represented By : Shri Dhanesh Bafna, Ms. Chandni Shah, Shri Hardik Nirmal & Ms. Riddhi Maru Department Represented By : Ms. A. Alankrutha

Section 115Section 143(3)Section 144C(5)Section 92C

records submitted by the assessee on merit and as per law. It is needless to say that assessee may be given a proper opportunity of being heard. In the result, the issue under consideration is remitted back to the file of Assessing Officer for statistical purpose. 48. In the result

Gdk Jewels Private Limited, New Delhi vs. ACIT, Circle-10(1), Delhi

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

ITA 952/DEL/2023[2017-18]Status: DisposedITAT Delhi07 Feb 2024AY 2017-18

Bench: Shri Saktijit Dey & Shri M. Balaganeshgdk Jewels Pvt. Ltd, Vs. Acit, 57, Ring Road, Lajpat Circle-10(1), Nagar-3, New Delhi Delhi (Appellant) (Respondent) Pan: Aaacg0095Q

For Appellant: Shri Pulkit Saini, AdvFor Respondent: Shri Vivek Kumar Upadhyay, Sr. DR
Section 143(3)Section 14ASection 36(1)(va)Section 68

That the Ld. CIT(A) sustained the addition of Rs. 8,87,81,056/- without providing any opportunity of being heard to the appellant which is against the law of natural justice. 8. That the above grounds are without prejudice to each other. 9. That the appellant craves the leave ... file of the ld CIT(A) for de novo adjudication in accordance with law. Needless to mention that the assessee be given reasonable opportunity of being heard. The assessee is at liberty to furnish further evidences, if any, in support of its contentions. Accordingly, the grounds raised by the assessee

Ghaziabad Development Authority, Ghaziabad vs. DCIT Circle Exemption, Ghaziabad

In the result, the appeal of the assessee in ITA

ITA 589/DEL/2023[2016-17]Status: DisposedITAT Delhi07 Feb 2024AY 2016-17
Section 10Section 11Section 12ASection 143(2)Section 2(15)Section 234A

well and restore the issue to the file of AO with direction to redecide the issue as per law by giving reasonable opportunity of being heard to the assessee.” 8.2 In the light of the orders of the Co-ordinate Bench as reproduced in the preceding paragraphs in the case

Ghaziabad Development Authority, Ghaziabad vs. DCIT E (Circle), Ghaziabad

In the result, the appeal of the assessee in ITA

ITA 305/DEL/2023[2018-19]Status: DisposedITAT Delhi07 Feb 2024AY 2018-19

Bench: SHRI M. BALAGANESH (Accountant Member), SHRI YOGESH KUMAR U.S. (Judicial Member)

Section 10Section 11Section 12ASection 143(2)Section 2(15)Section 234A

well and restore the issue to the file of AO with direction to redecide the issue as per law by giving reasonable opportunity of being heard to the assessee.” 8.2 In the light of the orders of the Co-ordinate Bench as reproduced in the preceding paragraphs in the case

ACIT, Circle-16(1), New Delhi vs. Magnum Steel Ltd, New Delhi

The appeal of the revenue is dismissed

ITA 1664/DEL/2022[2009-10]Status: HeardITAT Delhi07 Feb 2024AY 2009-10

Bench: Sh. N. K. Billaiya & Sh. Kul Bharatassessment Year: 2009-10 Acit Vs. Magnum Steel Ltd. Central Circle -16(1) 312, Essel House, 10 Asaf New Delhi Ali Road, New Delhi- 110002 Pan No.Aadcm6400E (Appellant) (Respondent) Appellant By Sh. Subhra Jyoti Chakrabotry, Cit Dr Respondent By Sh. Atriya G. C., Advocate Date Of Hearing: 05/02/2024 Date Of Pronouncement: 07/02/2024 Order Per N. K. Billaiya, Am:

Section 153ASection 154

ground that the AO could not have framed any order u/s. 154 of the Act without affording a reasonable and adequate opportunity of being heard to the assessee more so when the CIT(A) in A.Y.2010-11 did not give any direction for reopening / rectification of order ... powers conferred upon him by the provisions of section 154 of the Act and rectified the order suo-moto without affording any opportunity of being heard to the assessee. 10. On these facts we do not find any reason to interfere with the findings of the CIT(A). The appeal

Srs Ltd, Faridabad vs. DCIT, Central Circle-II, Faridabad

In the result, the appeal of the assessee is dismissed

ITA 9758/DEL/2019[2013-14]Status: DisposedITAT Delhi07 Feb 2024AY 2013-14

Bench: Dr. B. R. R. Kumarsh. Anubhav Sharma

For Appellant: Sh. Somil Agarwal, AdvFor Respondent: Sh. Javed Akhtar, CIT-DR
Section 234ASection 249(4)

erred in law and on facts in confirming the action of ld. AO in passing the impugned order without giving adequate opportunity of being heard and by not observing the principles of natural justice.” 3. At the outset, the ld. AR submitted that the appeal of the assessee has been

Haribhai Patel, Gandhinagar vs. The Income Tax Officer, Ward-2, Gandhinagar

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

ITA 791/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad06 Feb 2024AY 2017-18

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Respondent: Shri B. P. Makwana, Sr. DR
Section 144

foregoing paragraph, we find that the order has been passed without adherence to the principle of natural justice by affording a proper opportunity of being heard to the appellant by the First Appellate Authority by not issuing notices upon him physically as it was specifically mentioned in the Form No.35 ... file of the Ld. CIT(A) for considering the issue afresh on merit and to pass a reasoned order upon granting an opportunity of being heard to the ITA No. 791/Ahd/2023 (Haribhai Patel vs. ITO) A.Y.– 2017-18 - 3 – assessee and considering the evidence on record or any other evidence

Vikrambhai Ambalal Patel HUF, Dharmaj vs. The DCIT Circle 1(3) Vadodara (Now, the DCIT Circle 1(1)(1) Baroda), Baroda

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

ITA 645/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad06 Feb 2024AY 2013-14

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

For Respondent: Shri Ashok Kumar Suthar, Sr. DR
Section 143(3)

645/Ahd/2023 (Vikrambhai Ambalal Patel HUF vs. DCIT) A.Y.– 2013-14 - 3 – on merit and to pass a reasoned order upon granting an opportunity of being heard to the assessee and considering the evidence on record or any other evidence which the assessee may choose to file at the time

M/S. Vrajesh Agencies, Vadodara vs. The Income Tax Officer, Ward-1(2)(5), Vadodara

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

ITA 190/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad06 Feb 2024AY 2013-14

Bench: Shri Waseem Ahmed & Ms. Madhumita Royआयकर अपील सं./I.T.A. No. 190/Ahd/2023 ("नधा"रण वष" / Assessment Year : 2013-14) M/S. Vrajesh Agencies Income Tax Officer, बनाम/ A-9/5, Urmi Apartments, Ward 1(2)(5), Vadodara Vs. Fatehgunj, Vadodara "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabfv1170B (Appellant) .. (Respondent) Shri Hemant Suthar, Ar अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Shri Sushil Kumar Katiar, Sr. Dr 01/02/2024 Date Of Hearing 06/02/2024 Date Of Pronouncement O R D E R Per Ms. Madhumita Roy - Jm: The Instant Appeal Filed At The Instance Of The Assessee Is Directed Against The Order Dated 13.02.2023 Passed By The National Faceless Appeal Centre (Nfac), Delhi, Arising Out Of The Order Dated 18.03.2016 Passed By The Ito, Ward-1(2)(5), Vadodara, Under Section 143(3) Of The Act For Assessment Year 2013-14. 2. The Appeal Was Dismissed Ex Parte By Nfac, Delhi As None Appeared On Behalf Of The Appellant In Spite Of Several Notices Issued To The Appellant. However, Since Order Passed By The Ld.

For Respondent: Shri Sushil Kumar Katiar, Sr. DR
Section 143(3)Section 250(6)

file of the Ld. CIT(A) to re-consider the issue afresh on merit. The CIT(A) is further directed to grant proper opportunity of being heard to the appellant and also to consider the evidence on record or any other evidence which the assessee may choose to file

Kalyan, Purulia vs. CIT(Exemptions), Kolkata.

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

ITA 919/KOL/2023[00]Status: DisposedITAT Kolkata06 Feb 2024

Bench: Shri Sonjoy Sarma & Shri Girish Agrawal]

Section 12ASection 12A(1)(ac)

reconsider the application of assessee for permanent registration filed u/s 12AB of the Act in accordance with law after giving necessary opportunity of being heard to the assessee. In terms of above, the appeal of the assessee is allowed for statistical purposes. 6. In the result, the appeal