Tribunal held that  the assessment order was passed on March 22, 2013 and the Principal Commissioner had passed his order on March 30, 2015. Therefore, the order was within two years from the relevant date. According to the provisions of section 263(2) there was no mention about “service” of the order but only that the order shall be “made”. Tribunal also held that   it is mandatory to apply the principles of natural justice irrespective of whether there is any statutory provision. The assessee had not been afforded opportunity, much less sufficient opportunity to reply to the show-cause notice. The Principal Commissioner, hurriedly and without affording opportunity of hearing to the assessee, had passed the order in violation of the principle of audi alteram partem. He had committed a gross error in not providing any effective and reasonable opportunity of being heard to the assessee before passing the order. Accordingly, the revisional proceedings framed under section 263 by the Principal Commissioner were liable to be quashed.( AY.2010-11)