The Court held that CIT has to record his prima facie opinion in the show-cause notice, that the assessment order is erroneous and prejudicial to the interest of the revenue. Such prima facie view can be rebutted by the assessee in its reply to show cause notice. Accordingly, matter was set aside to the CIT to deal with the contentions of the assessee uninfluenced by any order of the Court. (AY. 2015-16)(SA No. 4 of 2019 dt. 07.01.2019)
Nordic Maritime Pte Ltd. v. CIT (2019) 308 CTR 855 / 178 DTR 110 (Uttarakhand)(HC)
S. 263 : Commissioner-Revision of orders prejudicial to revenue– CIT has to record his prima facie opinion in the show-cause notice, that the assessment order is erroneous and prejudicial to the interest of the revenue.