Lack of Opportunity of Being Heard: ITAT quashes Revision Order u/s 263

The ITAT quashed a revision order under Section 264 of the Income Tax Act due to a lack of opportunity for the taxpayer to be heard. The tribunal emphasized that any revision order must be issued with a fair opportunity for the taxpayer to present their case. In this case, the taxpayer was not given a chance to explain their position, which led to the quashing of the order. The ruling reinforces the importance of procedural fairness and due process in tax assessments, ensuring that taxpayers have the right to contest decisions before they are finalized.