The PCIT passed the revision order, without giving an opportunity of hearing. On writ allowing the petition the Court held that the procedure followed by the PCIT by passing the order without giving an opportunity of hearing to the assessee is in clear violation of section 263 of the Act and in breach of principle of natural justice. The petition was allowed. PCIT was directed to pass giving an opportunity of hearing within three moths from the date of communication of the order and in accordance with law.
Narayana Chetty Roja v. PCIT (2021) 206 DTR 421 (AP)(HC)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-COVID-19-Violation of principle of natural justice-Order passed without giving an opportunity of hearing was set aside-Matter remanded. [Art. 226]