9911796707
TMI Blog2022 (1) TMI 1411X X X X Extracts X X X X X X X X Extracts X X X X ..... have not given any opportunity to the assessee for proper hearing and principles of natural justice were violated - HELD THAT:- We have heard both the parties and perused all the relevant materials available on record. It is pertinent to note that at any stage of the assessment proceedings as well as appellate proceedings, i.e. before the CIT(A), no opportunity was granted to the assessee for pers ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of appeal raised by the assessee are as under : "1) The Ld. CIT(A) erred in law and on facts in confirming rejection of rectification application filed by the assessee u/s 154 of Income Tax Act, 1961 without considering the submission filed by the assessee on the online portal. 2) The order passed by the CIT(A) is bad in law as it was passed without adhering the principle of natural justice. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and due to above inadvertent mistake exemption available to the Trust was withdrawn and demand of Rs.13,46,070/- was raised on the Trust by intimation dated 28.02.2016. After receiving intimation raising demand, Trust has filed rectification application on e-filing portal to Central Processing Centre (CPC) to rectify the order and uploaded the correct particulars in ITR vide its application dated ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cer to give opportunity of hearing to the assessee. 6. The Ld. DR relied upon the rectification order and order of the CIT(A) but at the same time submitted that the assessee was not heard at any stage. 7. We have heard both the parties and perused all the relevant materials available on record. It is pertinent to note that at any stage of the assessment proceedings as well as appellate proceedi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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