Dismissing the appeal of the revenue , the Court held that, where the show cause notice under section 263 of the Act suggested only 2 issues but the order under section 263 of the Act directed the ld. AO to make enquiry and examine the two issues and a third issue, the Tribunal held that the third issue cannot form the basis for revision of assessment order under Section 263 of the Act. Order of the Tribunal upheld. ( AY. 2009 -10 ) (ITA No. 238 of 2018 dated April 19, 2022 )
PCIT v. Universal Music India Pvt. Ltd. (Bom)(HC) www.itatonline .org Editorial: CIT v. Amitabh Bacchan ( 2016) 384 ITR 200/ (69) taxmann.com 170 (SC) distinguished.
S. 263: Commissioner – Revision of orders prejudicial to revenue – Payment to specified persons – Revision proceedings cannot travel beyond the reasons given in show cause notice- 0rder of Tribunal is affirmed [ S. 40A(2)(b ) ]