https://www.taxtmi.com/caselaws?id=61567 A section 263 communication is treated as a pre-decisional hearing notice, so strict compliance with statutory notice-service requirements was not required. Limitation under section 263(2) was not established as barred because the assessee produced no material to displace the record showing timely passing of the revisional order. Revision was sustainable only to the extent that the assessment wrongly treated 45% of receipts as capital, making the order erroneous and prejudicial to the Revenue. The Commissioner could not, however, go beyond the show-cause notice and alter the basis of revision by taxing the entire receipts in the year of receipt; that part was set aside. en-us Tue, 11 Mar 2003 00:00:00 +0530 Thu, 13 Jan 2011 13:03:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=61567 A section 263 communication is treated as a pre-decisional hearing notice, so strict compliance with statutory notice-service requirements was not required. Limitation under section 263(2) was not established as barred because the assessee produced no material to displace the record showing timely passing of the revisional order. Revision was sustainable only to the extent that the assessment wrongly treated 45% of receipts as capital, making the order erroneous and prejudicial to the Revenue. The Commissioner could not, however, go beyond the show-cause notice and alter the basis of revision by taxing the entire receipts in the year of receipt; that part was set aside. Case-Laws Income Tax Tue, 11 Mar 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=61567