In the result, the appeal filed by the assessee is allowed
Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee
2. At the outset, the learned counsel for the appellant has submitted that as per the language of the section 263 it is apparently clear that opportunity of being heard has to be provided by Commissioner himself by way of issue of notice and show cause notices under section 263 of the Act and no other officer can perform this