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)]
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. 2009-2010) (ITA No. 238 of 2018 dated April 19, 2022)
PCIT v. Universal Music India Pvt. Ltd. (Bom.)(HC) www.itatonline .org

CORAM : Hon’ble Shri Justice K.R. Shriram and Hon’ble Shri Justice N.R. Borkar.