Once a request is made by the assessee before the Assessing Officer to give him an opportunity of hearing having regard to the fact that the assessment is a high-pitched assessment, ordinarily such an opportunity should be given. It would all depend on the nature of the issues involved in the matter. It is not necessary that in each and every case, the Assessing Officer has to provide personal hearing. Ultimately, it is the discretion of the Assessing Officer that should be exercised judiciously. Prima facie, it appeared that no inquiry had been undertaken by the Assessing Officer to verify the genuineness of the source. The assessee had also been denied personal hearing. On the facts and circumstances of the case the order of assessment was not valid. (AY.  2018-19)