Allowing the appeal of the assessee the Court held that  the Commissioner is duty bound to give an opportunity of being heard, while exercising the revisionary jurisdiction, to the assessee while enhancing or modifying the assessment or cancelling the assessment or directing for fresh assessment in conformity with the provisions contained under section 263.Accordingly the order passed by the Commissioner, without giving reasonable opportunity to the assessee which was affirmed by the Tribunal  was set aside. Directed the Commissioner to pass the order in conformity with the provisions of the Act in conformity with the provisions of the Act.   (AY.2014-15)