Appellate authority cannot refuse to grant same opportunity of hearing to petitioning assessee to defend order passed by original authority at instance of assessee because appeal is a continuous process of original application
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In all fairness, while hearing an appeal from the original authority, the CIT, the CBDT who is the appellate authority cannot deny the reasonable opportunity of hearing to the petitioning assessee at whose instance the impugned order came to be passed and which has become the subject-matter of appeal before the CBDT.
HIGH COURT OF MADRAS
S. Venkataramani
v.
CBDT
Writ Petition No. 16591 of 2009
December 2, 2009
