Held that when the th Assessing Officer in the original assessment order had taken cognisance of all the aspects and no case was made out by the Department that the assessment order was erroneous and prejudicial to the interests of the Revenue. For the disallowance of expenditure on exempt income, the assessee had not taken into account the equity shares investment as that has not yielded any dividend income in the particular year and, thus, the Principal Commissioner should have taken cognisance of this aspect. The Assessing Officer had categorically raised the query relating to disallowances and the assessee had given the details of disallowances under section\u00a014A\u00a0of the Act including the relevant monthly closing and opening balance of investment as well as the monthly closing details.\u00a0 The assessee had claimed at 30 per cent. of the deduction under section\u00a080JJAA\u00a0of the Act, which was in continuation of the earlier year in respect of employees employed in the earlier year and this was allowed by the section.\u00a0 The assessee had not claimed this as there was a loss due to fire. Revision order is bad in law. As regards the \u00a0issue of employees\u2019 compensation the scope of section\u00a0263\u00a0notice was expanded by the Principal Commissioner at the time of passing the order and the assessee was not confronted or given opportunity to present its case on the said issue. This issue was beyond the scope of notice and is\u00a0 not admissible for revision.(AY.2018-19)<\/p>\n","protected":false},"excerpt":{"rendered":"
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Assessing Officer has properly verified issues during original assessment-Expenditure on exempt income-Query raised in the course of assessment proceedings-Reply filed-Employment of new employees-In continuation of earlier years-Revision is not valid-Revision order is quashed-Revision on issue not included in notice-Revision is beyond scope of notice and not permissible. [S. 14A,80JJA, 143(3), R.8D]]<\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[21],"tags":[],"class_list":["post-50100","post","type-post","status-publish","format-standard","hentry","category-income-tax-act"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-d24","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/50100","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=50100"}],"version-history":[{"count":1,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/50100\/revisions"}],"predecessor-version":[{"id":50101,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/50100\/revisions\/50101"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=50100"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=50100"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=50100"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}