Assessee engaged in construction activities. Filed return of income declaring total income of Rs. 60.45 Lakhs. Return selected for limited scrutiny on issue of high ratio of refund to credit of tax deducted at source. Assessment proceedings were completed and total income was assessed at Rs. 62.95 Lakhs after making certain additions / disallowances. PCIT issued Show Cause Notice u/s. 263 alleging that (i) AO did not verified whether ICDS followed for allocation of contract cost and contract revenue, (ii) due to high refund-expenses were to examined and verified minutely through third party inquiry which was not undertaken and (iii) AO made addition and was required to initiate penalty proceedings u/s. 270A. However, in 263 Order, PCIT stated that AO was to examine financial statements of the assessee as to whether profit declared was correct or not, no documents filed with respect to increase in unsecured loans, advances given by the assessee-whether interest received or not ?, substantial increase in trade payables, confirmations from trade receivables, VAT / sales tax / service tax returns. Assessee alleged that said points were not mentioned in initial Show Cause Notice u/s. 263 and thus, assessee never got opportunity to file any documents in its defence. In revision proceedings-powers of PCIT are not limited to the matters contained in the initial show-cause notice, and therefore, during the course of revisionary proceedings, PCIT is empowered to enquire about other issued and pass appropriate orders and all that is required is that before recording any findings where are adversial in nature and which result in unsettling the position which has been accepted in the past, the assessee be put to notice and be allowed a reasonable opportunity to put forward its defence. However, the allegations raised by PCIT were linked to initial Show Cause Notice and it could not have been contended that PCIT did not provide sufficient opportunity of being heard. Further, during assessment, AO had verified costs and other expenses and AO had called relevant details alongwith supporting documentary evidences which were submitted by the assessee. AO passed Order holding that assessee did furnished some hand made bills, vouchers and even disallowed some expenses. Assessee had duly furnished ledger accounts of unsecured loans. Even in the assessment order, the AO has stated that books of accounts produced examined on test check basis. Thus, assessment order was passed after proper examination and verification and thus, Order u/s. 263 was set aside. (AY. 2017-18)