https://www.taxtmi.com/caselaws?id=284572 Section 28(6) of the Income-tax Act, 1922 did not require the Inspecting Assistant Commissioner to hear the assessee before granting previous approval for penalty. The reasonable opportunity of being heard was required at the stage of the penalty order under Section 28(3), while the approval under Section 28(6) operated only as administrative control over the Income-tax Officer and not as an additional adjudicatory hearing. The contention that a separate hearing was mandatory before approval therefore failed. en-us Tue, 15 Feb 1944 00:00:00 +0630 Tue, 26 Nov 2019 18:13:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=284572 Section 28(6) of the Income-tax Act, 1922 did not require the Inspecting Assistant Commissioner to hear the assessee before granting previous approval for penalty. The reasonable opportunity of being heard was required at the stage of the penalty order under Section 28(3), while the approval under Section 28(6) operated only as administrative control over the Income-tax Officer and not as an additional adjudicatory hearing. The contention that a separate hearing was mandatory before approval therefore failed. Case-Laws Income Tax Tue, 15 Feb 1944 00:00:00 +0630 https://www.taxtmi.com/caselaws?id=284572