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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

Idea Estate Pvt. Ltd., New Delhi vs. DCIT, Circle- 12(1), New Delhi

In the result, assessee’s appeal is allowed for statistical purposes

ITA 6308/DEL/2018[2013-14]Status: DisposedITAT Delhi13 Jul 2023AY 2013-14
For Appellant: Shri Tarun Kandhari, CAFor Respondent: Shri Anuj Garg, Sr. DR
Section 24Section 36

started earning income after 2 – 3 years. After examining the aforesaid aspects, AO shall pass an order after giving the assessee appropriate opportunity of being heard. 9. In the result, assessee’s appeal is allowed for statistical purposes. Order pronounced in the open court on this 13th day of July

The Income-Tax Officer -41(2)(2), Mumbai vs. Mr Jaiprakash Dhirajlal Barbhaya, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 475/MUM/2023[2010-2011]Status: DisposedITAT Mumbai12 Jul 2023AY 2010-2011

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms Kavitha Rajagopal, Hon’Bleincome Tax Officer – 41(2)(2) V. Jaiprakash Dhirajlal Barbhaya 301, Mahavir Apartment Room No. 636, 6Th Floor Nahur Road, Sarvodaya Nagar Kautilya Bhavan Mumbai – 400080 Bandra Kurla Complex Bandra(E), Mumbai - 400051 Pan: Agppb9599J (Appellant) (Respondent)

Section 143(1)Section 143(3)Section 148Section 271(1)(c)Section 274

called ambiguous wording in the notice [has not] impaired or prejudiced the right of the assessee to a reasonable opportunity of being heard”. It went onto observe that for sustaining the plea of natural justice on the ground of absence of opportunity, “it has to be established that prejudice

M/S Apollo Design Apparel Parks Limited, Mumbai vs. ACIT Circle-6(3)(1), Mumbai

In the result, the appeal by the assessee stands allowed for statistical purpose

ITA 1339/MUM/2023[2013-2014]Status: DisposedITAT Mumbai12 Jul 2023AY 2013-2014

Bench: Shri Br Baskaran & Shri Pavan Kumar Gadalem/S. Apollo Design Acit Circle 6(3)(1), Apparel Parks Limited, Room No.506,5Thflr, बनाम/ 382, N.M.Joshi Marg, Aayakar Bhavan, Vs. Chinchpokli, M.K.Road, Mumbai-400011. Mumbai-400020. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aahca0613R (""थ" / Respondent) (अपीलाथ" /Appellant)

Section 250Section 43B

appeal of the assessee and pass an order on the merits of the case. Needless to add, the assessee should be granted adequate opportunity of being heard. 12. In the result, the appeal by the assessee stands allowed for statistical purpose.” 8. We find the facts in the present case

Crown Seals Pvt Ltd., Mumbai vs. ITO Ward-6(2)(2), Mumbai

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

ITA 1319/MUM/2023[2011-12]Status: DisposedITAT Mumbai12 Jul 2023AY 2011-12

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Blem/S. Crown Seals Pvt. Ltd., V. Ito – Ward – 6(2)(1) Aayakar Bhavan, M.K. Road G-6-A, Laxmi Wollen Mill Estate Mumbai - 400020 Shakti Lane, Dr. E. Moses Road Mahalxmi, Mumbai - 400011 Pan: Aaccc8602K (Appellant) (Respondent)

Section 148Section 250Section 69C

above grounds of appeal.” 3. At the outset, Ld. Counsel for the assessee submitted that Ld.CIT(A) passed exparte order without providing adequate opportunity of being heard to the assessee, therefore, considering additions/disallowance made by the Assessing Officer, Ld. Counsel for the assessee requested that the matter may be restored ... keeping in view the additions/disallowance made by the Assessing Officer, we are of the opinion that assessee should be given one more opportunity of being heard in the interest of principles of natural justice. Thus, this appeal is restored to the file of the Ld.CIT(A) for denovo adjudication

Rockwell Automation Private Ltd., New Delhi vs. ACIT, Circle-19(1), New Delhi

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

ITA 1638/DEL/2022[2017-18]Status: FixedITAT Delhi12 Jul 2023AY 2017-18

Bench: Shri Shamim Yahya & Shri Challa Nagendra Prasadrockwell Automation India Private Acit, Circle 19(1), Limited, Vs. Delhi. 131, Functional Industrial Area, Patparganj, New Delhi.

For Appellant: Shri Ajit Jain, AdvocateFor Respondent: Shri Bhaskar Goswami, CIT(DR)
Section 143(1)Section 144C(10)Section 144C(13)Section 92C

provisions of Section 92CA read with section 143(1) of the Act and defying the principles of natural justice by not granting any opportunity of being heard to the Appellant; 1.2 not following the directions of Hon’ble DRP and violating the provisions of Section 144C(10) read with Section

Sandeep, Panipat vs. ITO, Ward- 4, Panipat

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

ITA 414/DEL/2019[2009-10]Status: DisposedITAT Delhi12 Jul 2023AY 2009-10
For Appellant: Shri J.B. Sharma, AdvocateFor Respondent: Ms. Kajal Singh, Sr. DR
Section 144Section 147Section 148

assessee and additional evidences being produced and thereafter pass an order as per law. Needless to add, assessee should be provided an opportunity of being heard. 10. In the result, this appeal filed by the assessee stands allowed for statistical purposes. Order pronounced in the open court on this 12th

Shri Riyazulhaq F Pathan, Belgavi vs. Income Tax Officer, Ward - 1, Nippani

The appeal is ALLOWED

ITA 21/PAN/2019[2015-16]Status: DisposedITAT Panaji12 Jul 2023AY 2015-16

Bench: Hon’Ble Shri S. S. Godara & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No. 21/Pan/2019 धििाारण वर्ा / Assessment Year : 2015-16 Shri Riyazulhaq F Pathan, Near Central Excise Quarter, Nipani Tq. Chikodi, Belagavi -591237 Pan:Ahdpp8150A . . . . . . . अपीलाथी / Appellant बिाम / V/S. Income Tax Officer, Ward-1, Nipani . . . . . . .प्रत्यथी / Respondent द्वारा / Appearances Assessee By : None Revenue By : Shri N. Shrikanth सुनवाई की तारीख / Date Of Conclusive Hearing : 10/07/2023 घोषणा की तारीख / Date Of Pronouncement : 12/07/2023 आदेश / Order Per G. D. Padmahshali, Am; The Appeal Is Directed Against The Order Of The Commissioner Of Income Tax (Appeals), Belagavi [‘Cit(A)’ In Short] Dt. 30/10/2018 Passed U/S 250 Of The Income-Tax Act, 1961 [‘The Act’ In Short] Which In Turn Ascended Out Of The Assessment Order Dt. 28/12/2017 Passed U/S 143(3) Of The Act By The Income Tax Officer, Ward-1, Nipani [‘Ao’ In Short].

For Appellant: NoneFor Respondent: Shri N. Shrikanth
Section 115BSection 133ASection 143(3)Section 250Section 250(6)Section 69Section 69A

speaking order in terms of section 250(6) of the Act and other applicable provisions of law after allowing the assessee a reasonable opportunity of being heard. 2. In result, the appeal is ALLOWED FOR STATISTICAL PURPOSE in above terms. In terms of rule 34 of ITAT Rules, the order

Mickey Shrivastva, Raipur vs. Assistant Commissioner of Income Tax -3(1), Raipur

In the result, appeal of the assessee is allowed

ITA 122/RPR/2019[2012-13]Status: DisposedITAT Raipur12 Jul 2023AY 2012-13

Bench: SHRI RAVISH SOOD (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

For Respondent: Shri Piyush Tripathi, Sr. DR
Section 143(3)Section 194C(5)Section 253Section 40a

erred in disallowing appeal on the basis of Assessment order passed by ACIT Circle 3(1) Raipur. As per principle of natural justice, opportunity of being heard not provided to the appellant. Prayed for one opportunity. 4. That the learned Assessing Officer further erred in charging interest u/s 234A, 234B

M/S M.D. Infra Developers, Surat vs. The Income Tax Officer, Ward - 3(3)(3), Surat

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

ITA 114/SRT/2023[2016-17]Status: HeardITAT Surat12 Jul 2023AY 2016-17

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.114/Srt/2023 Assessment Year: (2016-17) (Physical Hearing) M/S. M. D. Infra Developers, Vs. The Ito, Ward-3(3)(3), Block No.128, Mamta Park Society, Surat Near Shivani Show Room, Varachha Road, Kapodara, Surat – 39506. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aasfm7357A (Appellant) (Respondent) Shri Akshay M. Modi, Ca Appellant By Shri Vinod Kumar, Sr. Dr Respondent By Date Of Hearing 12/07/2023 Date Of Pronouncement 12/07/2023

Section 143(3)Section 250(6)

note that it is settled law that principles of natural justice and fair play require that the affected party is granted sufficient opportunity of being heard to contest his case. Therefore, without delving much deeper into the merits of the case, in the interest of justice, we restore the matter ... back to the file of Ld. CIT(A) for de novo adjudication and pass a speaking order after affording sufficient opportunity of being heard to the assessee, who in turn, is also directed to contest his stand forthwith. Therefore, we deem it fit and proper to set aside the order

Ramesh Kumar Mantri HUF, Jaipur vs. ITO WD 4(2), Jaipur

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

ITA 211/JPR/2023[2011-12]Status: DisposedITAT Jaipur12 Jul 2023AY 2011-12

Bench: Hon’ble SHRI SANDEEP GOSAIN (Judicial Member)

For Appellant: Shri Rajeev Sogani, CAFor Respondent: Shri Anoop Singh, Addl. CIT
Section 147Section 148

circumstances of the case and in law, the ld. CIT(A), NFAC has erred in deciding the appeal ex- parte without providing opportunity of being heard to the assessee. The action of the ld. CIT(A) is illegal, unjustified, arbitrary and against the facts of the case. Relief may please

Ruia Pradeep Bajranglal HUF, Mumbai vs. ITO - WD 25(3)(3), Mumbai

ITA 2110/MUM/2022[2011-12]Status: DisposedITAT Mumbai11 Jul 2023AY 2011-12

Bench: Shri Pavan Kumar Gadale & Shri S Rifaur Rahmanruia Pradeep Ito, Ward-25(3)(3), Bajranglal Huf Kautilya Bhavan, बनाम/ Ground Floor, Hari Bkc, Bandra, Vs. Nivas, Malviya Road, Mumbai-400051. Vile Parle (E), Mumbai-400057. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaahr0481E (""थ" / Respondent) (अपीलाथ" /Appellant)

For Appellant: Ms.Dinkle Hariya &For Respondent: Ms.Kavita Kaushik.DR
Section 143(1)Section 143(2)Section 147Section 148Section 250Section 68

facts the Learned Commissioner of Income-tax (Appeals), National Faceless Appeal Centre ["Ld. CIT (A)"] erred in not granting proper, sufficient and adequate opportunity of being heard to the Appellant while passing the appellate order. It is submitted that, in the facts and the circumstances of the case

Dayaram Agrawal, Raipur vs. Income Tax Officer-3(1), Raipur

In the result, the appeal filed by the assessee is allowed for statistical purposes in terms of the aforesaid observations

ITA 117/RPR/2023[2009-10]Status: DisposedITAT Raipur11 Jul 2023AY 2009-10

Bench: Shri Ravish Soodआयकर अपील सं./ Ita No. 117/Rpr/2023 "नधा"रण वष" / Assessment Year : 2009-10 Dayaram Agrawal H-1, Rajiv Nagar, Near Shiv Mandir, Raipur (C.G.) Pan : Acgpa8622C .......अपीलाथ" / Appellant बनाम / V/S.

For Appellant: Shri Bikram Jain, CAFor Respondent: Shri Choudhary N.C. Roy, Sr. DR
Section 147Section 148Section 250Section 251(1)(a)Section 251(2)Section 69

aside his order with a direction to dispose off the same on merits. Needless to say, the CIT(Appeals) shall afford a reasonable opportunity of being heard to the assessee in the course of the de novo appellate proceedings. The grounds of appeal raised by the assessee are disposed

Sanjay Mittal, Ambikapur vs. Principal Commissioner of Income Tax (Central), Bhopal

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

ITA 44/RPR/2022[2015-16]Status: DisposedITAT Raipur11 Jul 2023AY 2015-16

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No.44/Rpr/2022 "नधा"रण वष" / Assessment Year : 2015-16 Shri Sanjay Mittal 23/272, Agrasen Ward, Kharsia Road, Ambikapur, Sarguja (C.G.) Pan : Adtpm5911C .......अपीलाथ" / Appellant बनाम / V/S. The Pr. Commissioner Of Income Tax (Central), Bhopal ……""यथ" / Respondent

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri V.K Singh, CIT-DR
Section 132Section 143(3)Section 147Section 263Section 54F

aside the same with a direction to the A.O to frame a fresh assessment after conducting proper enquiries and affording a reasonable opportunity of being heard to the assessee. 4 Sanjay Mittal Vs. Pr. CIT (Central), Bhopal 5. The assessee being aggrieved with the order of the Pr. CIT passed

Assistant Commissioner of Income Tax, Circle 1(1), Raipur vs. M/S R.R. Industrial Corporation (India) Private Limited, Raipur

ITA 144/RPR/2018[2013-14]Status: DisposedITAT Raipur11 Jul 2023AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 144/Rpr/2018 "नधा"रण वष" / Assessment Year : 2013-14 The Assistant Commissioner Of Income Tax-1(1), Raipur (C.G.) .......अपीलाथ" / Appellant बनाम / V/S. M/S. R.R. Industrial Corporation (India) Pvt. Ltd., Station Road, Telghani Naka, Raipur (C.G.) Pan : Aaecr4291B ……""यथ" / Respondent

For Appellant: Shri Amit M. Jain, AdvocateFor Respondent: Smt. Ila M. Parmar, CIT-DR
Section 143(2)Section 143(3)Section 250(4)Section 68

aside proceedings re-adjudicate the aforesaid issue after confronting the requisite material to the assessee company and affording it a reasonable opportunity of being heard. 17. We, thus, in terms of our aforesaid observations set-aside the order of the CIT(Appeals) only to the limited extent he had accepted ... Balsasaria Holdings Pvt. Ltd., with a direction to him to re- adjudicate the same after confronting the requisite material and affording a reasonable opportunity of being heard to the assessee company. 18. Resultantly, the appeal filed by the revenue is partly allowed for statistical purposes in terms of our aforesaid

Maa Narmada Agrotech and Infrastures Ltd, Indore vs. The PCIT-1, Indore

In the result, appeal of assessee is allowed

ITA 117/IND/2022[2017-18]Status: DisposedITAT Indore11 Jul 2023AY 2017-18

Bench: Shri Vijay Pal Rao & Shri B.M. Biyanimaa Narmada Agrotech & Pcit Infrastructures Limited Indore -1 Ug-47, Trade Centre, Vs. Kanchan Bagh Main Road, Indore (Appellant / Assessee) (Respondent/ Revenue) Pan: Aafcm6285 P Assessee By Shri S.N. Goyal & Shri Pranay Goyal, Ars Revenue By Shri P.K. Mishra, Cit-Dr Date Of Hearing 31.05.2023 Date Of Pronouncement 11.07.2023

Section 139(1)Section 143(3)Section 263

Income Tax Act 1961, the said order is proposed to be revised under the said section. 5. You are hereby given an opportunity of being heard to explain as to why the proposed revision should not be carried out. For this purpose, your case is posted for hearing

R P Wood Products Pvt Ltd, Naya Bazar Ajmer vs. DCIT Central Circle Ajmer, Jaipur Road Ajmer

In the result, appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed

ITA 302/JPR/2023[2018-19]Status: DisposedITAT Jaipur11 Jul 2023AY 2018-19

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri C. M Agarwal (C.A.)For Respondent: Sh. Shailendra Sharma (CIT) a
Section 132Section 153ASection 271ASection 274

referred in this section meaning thereby that before imposing the penalty under section 271AAB, the AO must give show cause notice and an opportunity of being heard to the assessee. The requirement of giving an opportunity of being heard before imposing the penalty makes it abundantly clear that the penalty ... wherein, it directs that no order imposing penalty shall be made unless the assessee has been heard or has been given a reasonable opportunity of being heard. Therefore, from plain reading of section 271AAB of the Act, it is evident that the penalty cannot be imposed unless the assessee

Genesys International Corporation Ltd., Mumbai vs. DCIT, CPC, Banglore

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

ITA 440/MUM/2023[2018-19]Status: DisposedITAT Mumbai10 Jul 2023AY 2018-19

Bench: Shri Kuldip Singh & Shri Gagan Goyalgenesys International Corporation Ltd, 73A, Sdf Iii, 2Nd Floor, Seepz, Mumbai-400 096 Pan: Aaaca4528L ...... Appellant Vs. Dcit-Cpc Bangalore, Karnataka-560500 ..... Respondent

For Appellant: Shri Nishit Gandhi & Ms. Madhuri TambeFor Respondent: Shri Nihal Ranjan Samal, Sr. DR
Section 10ASection 115JSection 143(1)Section 143(2)Section 143(3)Section 250Section 36(1)

under challenge by the department including hearing before us. AO is directed to give assessee a 9 Genesys International Corporation Ltd reasonable opportunity of being heard. Resultantly ground no. 2 raised by the assessee is allowed for statistical purpose. 8. In the result appeal of the assessee is allowed

Mr Hariram Pahlumal Bhambhani, Mumbai vs. ACIT, Circle 9(2)(1), Mumbai

In the result, appeal is allowed for statistical purpose

ITA 1338/MUM/2023[2012-2013]Status: DisposedITAT Mumbai10 Jul 2023AY 2012-2013

Bench: Shri Vikas Awasthy () & Ms. Padmavathy S. ()

Section 142(1)Section 143(1)Section 143(3)Section 147Section 148Section 2(22)(e)

Bhambhani 1. The Ld. Commissioner of Income Tax (Appeals) has erred in dismissing the appeal of the assessee ex-parte, without providing reasonable opportunity of being heard to the assessee. 1.1 The Ld. Commissioner of Income Tax (Appeals) has dismissed the appeal of the assessee ex-parte for non - compliance ... portal has not allowed the uploading of the written submissions. The assessee has thus been denied the proper opportunity of being heard. As such the impugned order passed by the Commissioner of Income Tax (Appeals) is not as per law and is invalid. The same may be cancelled/quashed

Pramark Partnership Firm, Mumbai vs. CIT (A) NFAC, Delhi

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

ITA 1224/MUM/2023[2017-18]Status: DisposedITAT Mumbai10 Jul 2023AY 2017-18

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2017-18 Pramak/Partnership Firm Cit(A), Nfac, 2Nd Floor, Kuber Building, 98, Mumbai. Sheikh Memon Street, Zaveri Vs. Bazar, Mumbai-400002. Pan No. Aaafp 1969 L Appellant Respondent

For Appellant: Zeal SavlaFor Respondent: Ms. Indira Adakil, DR
Section 250

feel it appropriate to restore this appeal back to the file of the Ld. CIT(A) for deciding afresh after providing adequate opportunity of being heard to the assessee. The grounds raised by the assessee are accordingly allowed for statistical purposes. 4. In the result, the appeal of the assessee

M/S. Rajco Metal Indutries Pvt. Ltd, Mumbai vs. The Dy. Comm of Income Tax, Bangalore

In the result, the both the appeals of the assessee are dismissed

ITA 1541/MUM/2022[2018-19]Status: DisposedITAT Mumbai10 Jul 2023AY 2018-19

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2018-19 M/S Rajco Metal Industries Pvt. The Dcit, Cpc Bangalore, Ltd., Post Bag No. 2, Electronic City 19, Oriental Insurance Building, Vs. Post Office, Bangalore-560500. 31, Dr. V.B. Gandhi Marg, Fort, Mumbai-400023. Pan No. Aaacr 5185 N Appellant Respondent Assessment Year: 2019-2020 M/S Rajco Metal Industries Pvt. The Assessing Officer -2(3)(1), Ltd., Aayakar Bhavan, M.K. Road, 19, Oriental Insurance Building, Vs. Mumbai-400020. 31, Dr. V.B. Gandhi Marg, Fort, Mumbai-400023. Pan No. Aaacr 5185 N Appellant Respondent

For Appellant: Sanjay ParikhFor Respondent: Ms. Indira Adakil, DR
Section 143(1)Section 143(1)(a)

Faceless Appeal Centre [CIT(A)] erred on facts and in law in passing the order us. 250 without affording a reasonable and sufficient opportunity of being heard to theappellant. 2. The learned CIT(A) failed to appreciate that the appellant was prevented by a reasonable and sufficient cause from furnishing ... inference was called for on that account. 3. As the learned CIT(A) has passed an order without affording a reasonable and sufficient opportunity of being heard, the appellant prays that the order of the CIT(A) may be set aside and the CIT(A) may be directed to pass