2020 (6) TMI 672

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..... Das, Addl. CIT ORDER PER SHRI A.T.VARKEY, JM Both these appeals preferred by the assessee are against the separate orders of the Ld. CIT(A), Guwahati-1, dated 15.01.2018 and 19.12.2018 for AYs 2013-14 and 2014-15. 2. At the outset, it has been brought to our notice that there was a delay of 190 days and 221 days respectively to file appeals before us. We, however, from the perusal of....

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....Act (rectify the mistake) and consequently has made the addition. 4. According to AO, he fixed the matter on 03.08.2017 vide notice dated 18.07.2017, however, found that assessee did not appear before him, so he passed the section 154 of the Act order dated 11.08.2017. On appeal, the Ld. CIT(A) has dismissed the same ex parte, without going into the merits of the grounds raised by the assessee.....

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....ortunity of being heard, that the assessee could have placed the evidence before the appellate authority or before the Tribunal was really of no consequence for it was the assessment order that counted: that order had to be made after the assessee had been given a reasonable opportunity of being heard."(emphasis given by us) Therefore, in view of the above facts, and taking note of the decision....