Opportunity of Being Heard Mandatory Before Finalizing Section 263 Revision

Railesh Naik Vs PCIT (ITAT Surat)

ITAT Surat held that it is mandatory to provide proper opportunity of being heard to the assessee before finalization of revisionary proceedings under section 263 of the Income Tax Act. Accordingly, matter restore back to file of PCIT to pass fresh order after granting opportunity of hearing.

Facts- Assessee had not filed his returned of income for AY.2018-19. Specific information was flagged as per Risk Management Strategy of CBDT under the head “non-filing of return (NMS) cases” that assessee had purchased an immovable

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