Opportunity of hearing: Where assessee who was initially carrying out his business operations from Bhubaneswar had moved to Kolkata and had been filing returns there, merely because assessee did happen to be a director of a company which had been assessed in Balasore Circle would not automatically move jurisdiction of assessee’s case from Kolkata to Balasore without having to comply with mandatory requirement of section 124(3), and therefore assessee would continue to be subject to the jurisdiction of Kolkata. – Assistant Commissioner of Income-tax v. Biswajaya Dagara – [2023]