Dismissing the appeal of the assessee the Court held that ; the internal guidelines issued by the Central Board of Direct Taxes bereft of the statutory provisions in section 153D cannot bind the approving Authority, namely, the Joint Commissioner to comply with the principles of natural justice by the said Authority. The Assessing Authority undoubtedly has of course given adequate and reasonable opportunity of hearing to the assessee and all objections on merits were considered by him. Merely because, section 153D requires a prior approval of the draft assessment order by the higher Authority, namely, the Joint Commissioner in the present case, because the assessment order was passed by the authority below the rank of the Joint Commissioner, the provisions of the Act do not mandate that a fresh round of opportunity of hearing should be given to the assessee by such Authority, namely, Joint Commissioner even for approving draft assessment order. They are not even statutory instructions issued under section 119, which if beneficial to assessee have been held to be binding on the Authorities of the department. The assessee has also not been able to point out any prejudice caused to him on account of approving Authority not giving him an opportunity of hearing.