Held - There is no gainsaying that the impugned orders came to be passed without extending opportunity of personal hearing to the petitioner. In respect of the orders relating to three assessment years, the petitioner was not heard. While it is true that in reply in prescribed form given by the petitioner, in response to show-cause notice, the petitioner has indicated that he did not opt for personal hearing.

Learned AGP could not dispute the proposition enunciated from the decision in M/s. Alkem Laboratories Pvt. Ltd. (supra) relied by the learned advocate for the petitioner. Learned AGP in totality of the facts and circumstances, acted fairly to make a statement before the Court that the competent authority-respondent, would be giving personal hearing to the petitioner, which shall be done within three weeks from today and thereafter pass afresh orders in connection with the reassessment order.

The competent authority, respondent, will give opportunity of personal hearing to the petitioner within three weeks from today and pass in accordance with law, fresh orders within two weeks from the date of affording such personal hearing.