Opportunity of being heard: no penalty under sections 12 or 13 may be imposed without a reasonable hearing. No penalty under sections 12 or 13 may be imposed unless the assessee has been heard or has been given a reasonable opportunity of being heard; this requirement functions as a procedural precondition to the making of any penalty order and imposes an obligation on tax authorities to afford the assessee a chance to present their case before punitive action is finalised.