Gagandeep Garg v. PCIT (2023)108 ITR 137 (Amritsar) (Trib)

S. 263 : Commissioner-Revision of orders prejudicial to revenue-Limited scrutiny assessment-Principal Commissioner issued show-cause notice entirely different from issues selected for limited scrutiny-Assessing Officer cannot go beyond reasons of limited scrutiny-Principal Commissioner cannot pass revision order on other aspects-Revision order is quashed. [S. 143(3)]

Held, that the case was selected for limited scrutiny on unsecured loans from persons who had not filed their return of income, large increase in unsecured loans during the year and large squared up loans during the year. The issue for which the Principal Commissioner issued the show-cause notice was entirely different from the issues of selection of the case under limited scrutiny by the Assessing Officer. The Assessing Officer cannot go beyond the reasons for limited scrutiny and it would not be open to the Principal Commissioner to pass a revision order on other aspects and remit the matter to the Assessing Officer for fresh assessment. Revision order is bad in law. (AY.2015-16)