Held that the Principal CIT having given only four days’ time to the assessee to respond to the show cause notice and passed the revisional order under S.  263 ignoring the assessee’s reply seeking more time and without issuing any further notice, effective opportunity of being heard was denied to the assessee and therefore the  order  was  quashed (AY. 2016-17). The Tribunal also referred  Apex Court  in the case of Parashuram Pottery Works Co. Ltd v.ITO (1977) 106 ITR 1 (SC)  “ It has been said that the taxes are the price that we pay for civilization. If so, it is essential that those who are entrusted with the task of calculating and realising that price should familiarise themselves with the relevant provisions and become well-versed with the law on the subject. Any remissness on their part can only be at the cost of the national exchequer and must necessarily result in loss of revenue. At the same time, we have to bear in mind that the policy of law is that there must be a point of finality in all legal proceedings, that stale issues should not be reactivated beyond a particular stage and that lapse of time must induce repose in and set at rest judicial and quasi-judicial controversies as it must in other spheres of human activity.”