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    <title>Tax assessment revision u/s263 expanded beyond show-cause to ICDS, refunds, stock and non-filer purchases; quashed</title>
    <link>https://www.taxtmi.com/highlights?id=95574</link>
    <description>Revision under s.263 was held unsustainable where the revisional authority assumed jurisdiction on limited show-cause grounds but finally set aside the assessment on additional issues (ICDS/AS-7 compliance, refund verification, stock reconciliation, and purchases from non-filers) without issuing any notice on those new grounds; such expansion beyond the show-cause violates jurisdictional limits, vitiating the revision. On the original show-cause issues, the record showed adequate enquiry on creditor ageing and no demonstrated revenue prejudice, and post-assessment survey material could not retroactively render the completed assessment erroneous. Non-disallowance of delayed employees&#039; PF/ESI contributions was not treated as an error in light of then-prevailing HC law when the assessment was framed. The s.263 order was quashed and the appeal allowed - ITAT</description>
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    <pubDate>Wed, 31 Dec 2025 09:17:38 +0530</pubDate>
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      <title>Tax assessment revision u/s263 expanded beyond show-cause to ICDS, refunds, stock and non-filer purchases; quashed</title>
      <link>https://www.taxtmi.com/highlights?id=95574</link>
      <description>Revision under s.263 was held unsustainable where the revisional authority assumed jurisdiction on limited show-cause grounds but finally set aside the assessment on additional issues (ICDS/AS-7 compliance, refund verification, stock reconciliation, and purchases from non-filers) without issuing any notice on those new grounds; such expansion beyond the show-cause violates jurisdictional limits, vitiating the revision. On the original show-cause issues, the record showed adequate enquiry on creditor ageing and no demonstrated revenue prejudice, and post-assessment survey material could not retroactively render the completed assessment erroneous. Non-disallowance of delayed employees&#039; PF/ESI contributions was not treated as an error in light of then-prevailing HC law when the assessment was framed. The s.263 order was quashed and the appeal allowed - ITAT</description>
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      <pubDate>Wed, 31 Dec 2025 09:17:38 +0530</pubDate>
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