“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

Samveg Bhandari, Indore vs. Income Tax Officer, Delhi

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

ITA 291/IND/2023[2021-22]Status: DisposedITAT Indore06 Feb 2024AY 2021-22

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanisamveg Bhandari Ito- Nfac Bunglow No.1, Shalimar Delhi Township Vs. Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Ajfpb 6700N Assessee By Shri Subhash Chand Jain, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 05.02.2024 Date Of Pronouncement 06.02.2024

Section 143(1)Section 154

confirming the order u/s 154 of the Income Tax Act is invalid because the assesse was never granted any opportunity of being heard against such rejection of application u/s 154 of the Act of the assessee even alleged interest Income was already offered for tax as other income in Computation

Radhey Shyam Yadav, Jaipur vs. Income Tax Officer, Jaipur

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

ITA 814/JPR/2023[2011-2012]Status: DisposedITAT Jaipur06 Feb 2024AY 2011-2012

For Appellant: Ms. Nargis Parveen, CAFor Respondent: Mrs. Monisha Choudhary, Addl CIT-DR

Section 139(1)Section 144Section 148Section 69

both the authorities being the AO and CIT (Appeal) had erred at law as well as on facts in not providing the proper opportunity of being heard without indicating the servicing of the notices and thus the orders of both the authorities deserve to be set aside being against

Usha Infra, Ajmer vs. ITO Ward-1, Beawer

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

ITA 703/JPR/2023[2018-19]Status: DisposedITAT Jaipur06 Feb 2024AY 2018-19

Bench: SHRI SANDEEP GOSAIN (Judicial Member), DR MITHA LAL MEENA (Accountant Member)

For Appellant: Shri Vedant Agarwal, AdvFor Respondent: Shri A.S. Nehra, Addl CIT-DR

Section 144Section 68

case and in law also ld. Lower Authorities grossly erred in making the additions and passing the ex-parte order without providing opportunity of being heard. 2 USHA INFRA VS ITO, WARD 1, BEAWER 2. On the facts and circumstances of the case and in law the AO grossly erred

Anshul Dewat Singhal, Mumbai vs. Income Tax Officer-34(1)(1), Mumbai

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

ITA 3427/MUM/2023[2013-14]Status: DisposedITAT Mumbai06 Feb 2024AY 2013-14

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

For Appellant: MS. Vinita Shah, CAFor Respondent: Shri Manoj Kumar Sinha, Sr. DR

Section 142(1)Section 144

Learned CIT(A) as well as the Learned Assessing Officer has erred in passing the ex- parte order, without granting sufficient opportunity of being heard to the appellant. 2. On the facts and circumstances of the case as well as in law, the Learned CIT(A) has erred in confirmation

Staark Accessories Private Limited, Mumbai vs. ACIT, Circle 13(2)(2)

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

ITA 2418/MUM/2023[2016-17]Status: DisposedITAT Mumbai06 Feb 2024AY 2016-17

Bench: Shri Kuldip Singh & Shri Gagan Goyalm/S. Staark Accessories Pvt. Ltd., A-20, Virwani Industrial Estate Goregaon East, Mumbai- 400063, Pan: Aatcs1816J ...... Appellant Vs. Acit-13(2) (2), Aayakar Bhavan, Maharishi Karve Road, Mumbai- 400020 ..... Respondent

For Appellant: Shri Ashwin S. Chhag, Ld. ARFor Respondent: Shri Prasoon Kabra, Ld. DR

Section 143(2)Section 143(3)Section 145Section 250Section 44A

General or] Director General or [Principal Chief Commissioner or] Chief Commissioner or [Principal Commissioner or] Commissioner may, after giving the assessee a reasonable opportunity of being heard in the matter, wherever it is possible to do so, and after recording his reasons for doing so, transfer any case from ... Chief Commissioner or [Principal Commissioner or] Commissioner from whose jurisdiction the case is to be transferred may, after giving the assessee a reasonable opportunity of being heard in the matter, wherever it is possible to do so, and after recording his reasons for doing so, pass the order; (b) where

Fulford (India) Ltd, Mumbai vs. DCIT Cir 2(1), Mumbai

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

ITA 338/MUM/2014[2009-10]Status: DisposedITAT Mumbai06 Feb 2024AY 2009-10

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआ.अ.सं.338/मुं/2014(िन.व.2009-10) Fulford (India) Limited, Platina Building, 8Th Floor, C-59, G-Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400 098 Pan: Aaacf-1795-L ...... अपीलाथ"/Appellant बनाम Vs. Dy.Commissioner Of Income Tax, Circle 2(1), Room No.561, 5Th Floor, Aaykar Bhavan, M.K.Road, Mumbai – 400 020. ..... "ितवादी/Respondent Assessee By : Shri P.J. Pardiwala, Sr. Advocate With Shri Madhur Agrawal, Advocate Revenue By : Dr. Yogesh Kamat, Cit-Dr & Shri Ujjwal Kumar Chavan, Sr.Ar सुनवाई क" ितिथ/ Date Of Hearing : 10/11/2023 घोषणा क" ितिथ/ Date Of Pronouncement : 06/02/2024 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Assessment Order Dated 13/12/2013 Passed U/S. 143(3) R.W.S. 144C(13) Of The Income Tax Act, 1961 [In Short ‘The Act’], For The Assessment Year 2009-10. 2. The Facts Of The Case In Brief Are: The Assessee/Appellant Is Engaged In The Business Of Manufacturing & Distribution Of Pharmaceutical Products In 2 India. The Assessee Is A Subsidiary Of Schering-Plough Corporation, Usa. During The Period Relevant To The Assessment Year Under Appeal, The Assessee Entered Into Various International Transactions With Its Associated Enterprise(Ae). During The Course Of Assessment Proceedings The Transfer Pricing Officer (Tpo) Made Adjustment In Respect Of Following International Transactions: Sl.No. Description Of International Transaction Adjustment Made By Tpo (Amount In Rs.) 1. Import Of Active Pharmaceutical 4,81,96,325 Ingredients (Apis) 2 Import Of Finished Drug Formulations (Fdf) 15,75,53,000 Total 20,57,49,325

For Appellant: Shri P.J. Pardiwala, Sr. Advocate with Shri Madhur Agrawal, AdvocateFor Respondent: Dr. Yogesh Kamat, CIT-DR &

Section 143(3)

direct the appellant to file the relevant documents/evidence before the AO. Needless to say the AO would give the relevant information and reasonable opportunity of being heard to the appellant before finalizing the order. We also want to make it clear that all the cases relied on by both

Minosha India Limited, Delhi vs. DCIT Circle 16(1), New Delhi

Appeal of the assessee is allowed for statistical purposes

ITA 2129/DEL/2023[2012-13]Status: HeardITAT Delhi06 Feb 2024AY 2012-13

Bench: Shri Narendra Kumar Billaiya & Shri Kul Bharatassessment Year: 2012-13

Section 143(3)Section 32(1)

aside and the matter be restored to the file of learned CIT(A) for decision afresh on merit after providing reasonable opportunity of being heard and considering the submissions made by the assessee . 4. Learned DR opposed the submissions made on behalf of the assessee and relied on the order ... afresh, on merits, 4 after considering the submissions made on behalf of the assessee in support of its claim, of course, affording adequate opportunity of being heard to the assessee. We order accordingly 6. Appeal of the assessee is allowed for statistical purposes. Order pronounced in open court

Bsc C&C Joint Venture, New Delhi vs. DCIT, Circle-61(1), New Delhi

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

ITA 2284/DEL/2022[2018-19]Status: DisposedITAT Delhi06 Feb 2024AY 2018-19

Bench: SHRI G.S. PANNU (Vice President), SHRI ANUBHAV SHARMA (Judicial Member)

For Appellant: Sh. Tarandeep Singh, AdvFor Respondent: Sh. Vivek Kumar Upadhyay, Sr. DR

Section 143(3)Section 234BSection 40Section 801A(4)(i)Section 80I

prayed accordingly. 3. Virtual Hearing: Your goodself has allowed Virtual Hearing of the case. We would like to avail the said opportunity of being heard virtually. However, we would request your goodself to kindly give us some time to submit the pending details of expenses and we would request

Maharashtra Feeds P. Ltd., New Delhi vs. ACIT, Central Circle, Faridabad

In the result, the appeals of the assessee are allowed

ITA 1254/DEL/2021[2015-16]Status: DisposedITAT Delhi06 Feb 2024AY 2015-16

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. K. Sampath, Adv. &For Respondent: Ms. Smita Singh, Sr. DR

Section 153ASection 154Section 208Section 234ASection 234CSection 243CSection 245CSection 245DSection 245D(1)Section 245D(4)

unless the authority concerned has given notice to the assessee of its intention so to do and has allowed the assessee a reasonable opportunity of being heard. Chapter XVII - Collection and Recovery of Tax Liability for payment of advance tax. 207. Tax shall be payable in advance during any financial

Maharashtra Feeds P. Ltd., New Delhi vs. ACIT, Central Circle, Faridabad

In the result, the appeals of the assessee are allowed

ITA 1253/DEL/2021[2014-15]Status: DisposedITAT Delhi06 Feb 2024AY 2014-15

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. K. Sampath, Adv. &For Respondent: Ms. Smita Singh, Sr. DR

Section 153ASection 154Section 208Section 234ASection 234CSection 243CSection 245CSection 245DSection 245D(1)Section 245D(4)

M R Apparels P.Ltd, New Delhi vs. Prcit-6, New Delhi

In the result, the appeal of the assessee is dismissed

ITA 198/DEL/2020[2015-16]Status: DisposedITAT Delhi06 Feb 2024AY 2015-16

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. Nitin Goyal, CAFor Respondent: Sh. Subhra Jyoti Chakraborty, CIT-DR

Section 143(3)Section 263

uncalled for. 2. That the Ld. PR. CIT has erred in passing the order without giving due opportunity of being heard to the appellant, • Because, the appellant had not received any alleged email for re-fixing the matter; • Because the appellant has made a request ... order ex-parte in hurry. 2. Ground no 2 "That the Ld. PR. CIT has erred in passing the order without giving due opportunity of being heard to the appellant, • Because, the appellant had not received any alleged email for re-fixing the matter; • Because the appellant has made

Castmaster Industries Pvt. Ltd., New Delhi vs. ACIT, Circle- 5(2), New Delhi

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

ITA 88/DEL/2018[2014-15]Status: DisposedITAT Delhi06 Feb 2024AY 2014-15

Bench: Shri Shamim Yahya & Ms. Astha Chandracastmaster Industries Pvt. Ltd., Vs. Acit, Circle 5 (2), C-5, Maharani Bagh, New Delhi. New Delhi – 110 065. (Pan : Aaacr2847R) (Appellant) (Respondent)

For Appellant: Ms. Manju Goel, CAFor Respondent: Shri Vivek Kumar Upadhyay, Sr. DR

Section 115JSection 143(3)

shall compute the book profit as per provisions of section 115JB of the Act. Needless to add, assessee should be granted adequate opportunity of being heard. 8. In the result, this appeal filed by the assessee is partly allowed for statistical purposes. Order pronounced in the open court on this0

M/S. Prime Property Development Corporation Ltd, Mumbai vs. ACIT Circle 10 (3) (2), Mumbai

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

ITA 3290/MUM/2023[2013-14]Status: DisposedITAT Mumbai05 Feb 2024AY 2013-14

Bench: Shri B.R. Baskaran (Am) & Shri Pavan Kumar Gadale (Jm)

order passed by the learned CIT(A) and restore all the issues to his file for adjudicating them afresh, after affording adequate opportunity of being heard. We also direct the assessee to fully cooperate with the learned CIT(A) for expeditious disposal of the appeal. 4. In the result, appeal

Sarva Capital Llc, New Delhi vs. ACIT Circle International Tax 3(1)(2), New Delhi

In the result, appeal is partly allowed

ITA 2073/DEL/2023[2020-21]Status: DisposedITAT Delhi05 Feb 2024AY 2020-21

Bench: Shri Kul Bharat & Dr. B. R. R. Kumar

For Appellant: Sh. Nirbhay Mehta, AdvFor Respondent: Sh. Vizay B.Vasanta, CIT-DR

Section 112Section 143(2)Section 143(3)Section 144C(13)Section 270A

facts and circumstances of the case and in law, the La. AO grossly erred in violating principles of natural justice without providing reasonable opportunity of being heard to the Appellant during the course of assessment proceedings, and without considering the submission and material/ evidence filed on record. 4. That

Matrix Clothing Pvt.Ltd., Gurgaon vs. ACIT, Special Range-6, New Delhi

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

ITA 8183/DEL/2019[2016-17]Status: DisposedITAT Delhi05 Feb 2024AY 2016-17

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

For Appellant: Shri Salil Aggarwal, Sr. AdvFor Respondent: Shri Vipul Kashyap, Sr. DR

Section 28Section 36(2)Section 80J

perverse and have been recorded with preconceived notions and without considering the submissions/evidences/material produced on record and also without providing fair and proper opportunity of being heard, hence such findings are vitiated and deserves to be deleted. 2. That the learned Commissioner of Income Tax (Appeals) has grossly erred ... perverse and have been recorded with preconceived notions and without considering the submissions/evidences/material produced on record and also without providing fair and proper opportunity of being heard, hence such findings are vitiated and deserves to be deleted. 3. That the learned Commissioner of Income Tax (Appeals) has grossly erred both

Paschim Gujarat Vij Co. Ltd., Vadodara vs. The Pr.CIT-2, Baroda

The appeal of the assessee is partly allowed

ITA 911/AHD/2019[2014-15]Status: DisposedITAT Ahmedabad02 Feb 2024AY 2014-15

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarिनधा"रण वष"/Assessment Year: 2014-15 The Principal Commissioner Of Paschim Gujarat Vij. Co. Ltd., Income-Tax-2, Off. Nana Mava Main Road, Vs. Vadodara Laxmi Nagar, Rajkot-360004 Pan : Aadcp 1453 C अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Mehul K. Patel, Advocate Revenue By : Shri Sudhendu Das, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 29.01.2024 घोषणा क" तारीख /Date Of Pronouncement: 02.02.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Learned Principal Commissioner Of Income-Tax, Vadodara-2 [Herein-After Referred To As “Pcit”] Dated 27.03.2019, In Exercise Of His Revisionary Powers Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], For The Assessment Year (Ay) 2014-15. 2. The Grounds Raised By The Assessee Are As Under:- “(1) That On Facts & In Law, The Learned Cit Has Grievously Erred In Assuming Jurisdiction U/S.263 Of The Act, Without Recording A Satisfaction As To How The Assessment Order Passed U/S 143(3) Of The Act Is Erroneous & Prejudicial To The Interest Of Revenue. (2) That On Facts & In Law, The Proceedings U/S.263 Are Void As The Original Assessment Order Was Passed U/S.143 (3) Of The Act After Due Inquiry & Application Of Mind / & Is Not Erroneous & Prejudicial To The Interest Of The Revenue.

For Appellant: Shri Mehul K. Patel, AdvocateFor Respondent: Shri Sudhendu Das, CIT-DR

Section 143Section 143(3)Section 263Section 32(1)(iia)

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

Madhya Gujarat Vij Company Ltd., Vadodara vs. The Pr. Commissioner of Income Tax, -2, Vadodara

The appeal of the assessee is allowed

ITA 909/AHD/2019[2013-14]Status: DisposedITAT Ahmedabad02 Feb 2024AY 2013-14

Bench: Mrs. Annapurna Gupta & Shri T.R. Senthil Kumarिनधा"रण वष"/Assessment Year: 2013-14 Madhya Gujarat Vij Co. Ltd., The Principal Commissioner Of Vs. Sardar Patel Vidyut Bhavan, Income-Tax-2, Race Course, Vadodara-390007 Vadodara Pan : Aadcm 7439 H अपीलाथ" अपीलाथ"/ (Appellant) अपीलाथ" अपीलाथ" "" "" यथ" "" "" यथ" यथ"/ (Respondent) यथ" Assessee By : Shri Mehul K. Patel, Advocate Revenue By : Shri Sudhendu Das, Cit-Dr सुनवाई क" तारीख/Date Of Hearing : 29.01.2024 घोषणा क" तारीख /Date Of Pronouncement: 02.02.2024 आदेश आदेश/O R D E R आदेश आदेश Per Annapurna Gupta: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Learned Principal Commissioner Of Income-Tax, Vadodara-2 [Herein-After Referred To As “Pcit”] Dated 27.03.2019, In Exercise Of His Revisionary Powers Under Section 263 Of The Income-Tax Act, 1961 [Hereinafter Referred To As “The Act”], For The Assessment Year (Ay) 2013-14. 2. The Grounds Raised By The Assessee Are As Under:- “(1) That On Facts & In Law, The Learned Cit Has Grievously Erred In Assuming Jurisdiction U/S.263 Of The Act, Without Recording A Satisfaction As To How The Assessment Order Passed U/S 143(3) Of The Act Is Erroneous & Prejudicial To The Interest Of Revenue. (2) That On Facts & In Law, The Proceedings U/S.263 Are Void As The Original Assessment Order Was Passed U/S.143 (3) Of The Act After Due Inquiry & Application Of Mind / & Is Not Erroneous & Prejudicial To The Interest Of The Revenue.

For Appellant: Shri Mehul K. Patel, AdvocateFor Respondent: Shri Sudhendu Das, CIT-DR

Section 139(1)Section 143Section 143(3)Section 263Section 36(1)(vii)Section 43B

Akt Construction Private Limited., Kolkata vs. ITO, Ward-10(3), Kolkata.

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

ITA 901/KOL/2023[2015-16]Status: DisposedITAT Kolkata02 Feb 2024AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Girish Agrawal]

prayed that grounds raised in the instant appeal may be restored to the ld. CIT(A) for adjudicating afresh after providing reasonable opportunity of being heard. 4. Per contra, ld. DR was fair enough not to oppose this request of the ld. counsel for the assessee. 5. We have heard ... adjudicating afresh to pass a speaking order after considering the submission made by the assessee for which reasonable opportunity of being heard should be provided. The assessee also directed to remain vigilant and file necessary documents in support of its grounds of appeal and should not take any further adjournment

Rabin Debnath, Siliguri vs. DCIT, Cir-1, Siliguri, Kolkata

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

ITA 1319/KOL/2023[2017-18]Status: DisposedITAT Kolkata02 Feb 2024AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Girish Agrawal]

Dhanania Rubber Limited, Kolkata vs. Pr.C.I.T.-3, Kolkata

In the result, the appeal of the assessee stands dismissed

ITA 167/KOL/2020[2014-15]Status: DisposedITAT Kolkata02 Feb 2024AY 2014-15

Bench: Shri Sanjay Garg & Shri Girish Agrawali.T.A. No.167/Kol/2020 Assessment Year : 2014-15 Dhanania Rubber Ltd.……..…..…......................…...……………....Appellant 10, Paymental Garden Lane, Kolkata – 700015. [Pan: Aaacd9341G] Vs. Pcit-3, Kolkata……..........…..........................................…..…..... Respondent Appearances By: Shri Anuj Mussadi, Ar, Appeared On Behalf Of The Appellant. Shri Rakesh Kumar Das, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 22, 2024 Date Of Pronouncing The Order : February 02, 2024 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 20.03.2019 Of The Principal Commissioner Of Income Tax [Hereinafter Referred To As ‘Pr. Cit’] Exercising His Revision Jurisdiction U/S 263 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’).

Section 143(3)Section 250Section 263

computation of long term capital gain and deduction claimed by the assessee. It was also directed that the Assessing Officer will provide reasonable opportunity of being heard to the assessee and to produce the documents & evidences to substantiate its claim and thereafter the Assessing Officer would pass a fresh assessment