The assessee, a Regional Rural Bank, challenged an ex parte order of the Commissioner (Appeals), contending that although it had responded to the notice of hearing, the supporting attachments could not be uploaded due to technical glitches. Further, the subsequent notice contained an incorrect hearing date and though a corrected notice was later issued, the assessee did not receive it and remained under the impression that the original date continued to apply. The Tribunal held that the discrepancy in the hearing dates had deprived the assessee of a reasonable opportunity of being heard. Accordingly, the ex parte order was set aside and the matter was restored to the Commissioner (Appeals) for fresh disposal after granting adequate opportunity of hearing. The assessee was directed to extend full co-operation in the appellate proceedings (AY. 2020-21)