Assessee, an NRI residing in Dubai, held NRE deposits in HDFC Bank and Standard Chartered Bank, claimed income only as interest on NRE deposits exempt under section 10(15), and was alleged by the department to have not filed a return for the relevant assessment year. The case was flagged under Risk Management Strategy, and a show-cause under section 148A(b) was issued. An order under section 148A(d) held it to be a fit case for reassessment, alleging escapement of income of about Rs. 3.05 crores, and a notice under section 148 was issued.  During reassessment, notices under section 142(1) were issued, and a show-cause proposed addition of about Rs. 3.05 crores and fixed a personal hearing on 25-3-2023.  Assessee sought 15 days’ adjournment. However, without granting a personal hearing despite assessee’s request, the Assessing Officer passed a reassessment order on 31-3-2023 under section 147 read with section 144B, adding about Rs. 3.05 crores. On writ, the Court held that it is a fundamental proposition of law that the other side should be heard before any order is passed, and maxim audi alteram partem is broad enough to include a rule against bias since a fair hearing is a must for an unbiased hearing. Since hearing was not granted to assessee despite a request being made, the reassessment order was quashed and set aside. (AY. 2018-19)