Allowing the petition the Court held that when the law specifically requires the giving of an opportunity of being heard, that must be followed lest such failure render the order legally fragile on the anvil of breach of principles of natural justice. The procedure followed by the Principal Commissioner in passing the order without giving an opportunity of hearing to the assessee was in violation of section 263 and in breach of principles of natural justice. The order was set aside and the matter was remitted to the Principal Commissioner.