https://www.taxtmi.com/caselaws?id=326146 A show cause notice issued in appellate proceedings sought to change the assessee's status from a partnership firm to an association of persons, but the Court held that the notice was unsustainable because the assessee had consistently been assessed as a partnership firm and the premise that a firm cannot be a partner in another firm was contrary to law. The Court also refused to let the Revenue improve the notice by supplying new reasons not contained in it, and left open the wider question of the Commissioner (Appeals)'s jurisdiction under section 251. The notice and the order sustaining it were set aside. en-us Thu, 24 Mar 2016 00:00:00 +0530 Mon, 02 May 2016 15:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=326146 A show cause notice issued in appellate proceedings sought to change the assessee's status from a partnership firm to an association of persons, but the Court held that the notice was unsustainable because the assessee had consistently been assessed as a partnership firm and the premise that a firm cannot be a partner in another firm was contrary to law. The Court also refused to let the Revenue improve the notice by supplying new reasons not contained in it, and left open the wider question of the Commissioner (Appeals)'s jurisdiction under section 251. The notice and the order sustaining it were set aside. Case-Laws Income Tax Thu, 24 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=326146