The assessee’s assessment was completed under section 143(3). Revision notice u/s 263 was issued on two grounds, but in final order Commissioner also directed AO to enquire into payments to related parties u/s 40A(2)(b) which was never mentioned in notice. Tribunal set aside the revision, and High Court  upheld, holding that revision cannot be based on an issue not part of show cause notice. (AY. 2009-10)