No denial of hearing by CIT(A) due to non-payment of tax if sum seized from assessee exceeded tax du

IT: Where Commissioner (Appeals) denied hearing of appeal on plea that assessee had failed to pay due tax on returned income and had defaulted in terms of provisions of section 249(4)(a), since amount that had been seized by revenue from assessee was far in excess of amount of tax payable on returned income, assessee could not have been denied hearing