Allowing the petition the Court held that  S. 148A(b) begins with provide an opportunity of being heard to the assessee. Hearing does not mean filing reply to the show-cause notice. If the provision of this section contemplates opportunity of being heard that has to be construed as personal hearing. Therefore, there is no substance in the submission of Revenue’s counsel that an opportunity of being heard to the assessee contemplated under s. 148A(b) does not necessarily mean personal hearing. Court held that opportunity of being heard under s. 148A(b) means an opportunity of personal hearing to the assessee. On facts  no such opportunity of being heard was given to the assessee before passing order and issuing notice. Order and notice are unsustainable. The notice and order is set aside. The assessee is directed to appear before the respondent on or before 27th Oct., 2023 with all the relevant document in his possession of being heard. After considering the submission of the assessee, the AO is required to pass a fresh order, and thereafter, proceed with the matter. (AY. 2019-20)