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The ITAT held that the CIT(A) lacked jurisdiction to enhance the assessment under section 251 due to failure to issue the mandatory enhancement notice under section 251(2). The addition based on net profit at 8% of turnover was deleted as the assessee was not afforded an opportunity to respond to the enhancement proposal, rendering the addition invalid. Consequently, the addition relating to net profit was set aside, and the assessee's grounds were allowed.
The ITAT held that the CIT(A) lacked jurisdiction to enhance the assessment under section 251 due to failure to issue the mandatory enhancement notice under section 251(2). The addition based on net profit at 8% of turnover was deleted as the assessee was not afforded an opportunity to respond to the enhancement proposal, rendering the addition invalid. Consequently, the addition relating to net profit was set aside, and the assessee's grounds were allowed.
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