https://www.taxtmi.com/caselaws?id=784213 The dominant issue was whether the PCIT validly assumed revisionary jurisdiction under s.263 by basing the revision order on issues not put to the assessee in the show-cause notice. The ITAT held that s.263 jurisdiction is confined to matters for which a specific show-cause is issued; introducing fresh grounds (ICDS/AS-7 compliance, refund verification, opening/closing stock mismatch, and purchases from non-filers) without notice rendered the revision beyond jurisdiction, so the s.263 order was quashed. On the noticed issues, the ITAT further held the AO had made adequate enquiries, post-assessment survey material could not retroactively establish error, and non-disallowance of employees' PF/ESI (then supported by HC precedent) was not an "error" meeting the twin conditions of "erroneous and prejudicial"; the assessee's appeal was allowed. en-us Fri, 24 Oct 2025 00:00:00 +0530 Mon, 29 Dec 2025 14:51:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784213 The dominant issue was whether the PCIT validly assumed revisionary jurisdiction under s.263 by basing the revision order on issues not put to the assessee in the show-cause notice. The ITAT held that s.263 jurisdiction is confined to matters for which a specific show-cause is issued; introducing fresh grounds (ICDS/AS-7 compliance, refund verification, opening/closing stock mismatch, and purchases from non-filers) without notice rendered the revision beyond jurisdiction, so the s.263 order was quashed. On the noticed issues, the ITAT further held the AO had made adequate enquiries, post-assessment survey material could not retroactively establish error, and non-disallowance of employees' PF/ESI (then supported by HC precedent) was not an "error" meeting the twin conditions of "erroneous and prejudicial"; the assessee's appeal was allowed. Case-Laws Income Tax Fri, 24 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784213