Allowing the petition the Court held that ,  S. 220(3) vests discretion with the AO to grant some relief to the assessee who falls with in its parameters . This discretion is to be exercised according to the rules of reasons of justice .It is not a mughal discretion . Principle of natural justice being part of Art.14 of the constitution are in built in every public power subject to all just exceptions. Accordingly  when an opportunity of personal audience is requested the law requires due consideration. Hence rejection of application without affording an opportunity of hearing is set aside AO is  directed to pass speaking order after giving an opportunity of hearing . (WP Nos . 106708/ 106849 of 2019 dt 25 -03 -2019)   (AY. 2013 -14)