Section 263: Opportunity to be Heard is Crucial, Not Just a Formality; Non-Compliance Voids Tax Order.

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....Revision u/s 263 - Opportunity of being heard is little more than serving a notice on assessee. It is not an empty formality. - Since the mandatory requirement of opportunity of being heard has not been provided to assessee, the order passed by CIT is void ab-initio - AT....