https://www.taxtmi.com/caselaws?id=788420 An appellate authority cannot enhance income without first issuing the mandatory show cause notice and giving the assessee a reasonable opportunity of hearing; enhancement made in breach of section 251(2) was unsustainable. The claim that salary for overseas services was not taxable in India, and the related TDS credit, depended on factual verification of residence, period of stay abroad, nature of services, and treaty entitlement, so the matter required remand for fresh examination by the jurisdictional Assessing Officer. en-us Thu, 05 Mar 2026 00:00:00 +0530 Sat, 21 Mar 2026 08:29:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788420 An appellate authority cannot enhance income without first issuing the mandatory show cause notice and giving the assessee a reasonable opportunity of hearing; enhancement made in breach of section 251(2) was unsustainable. The claim that salary for overseas services was not taxable in India, and the related TDS credit, depended on factual verification of residence, period of stay abroad, nature of services, and treaty entitlement, so the matter required remand for fresh examination by the jurisdictional Assessing Officer. Case-Laws Income Tax Thu, 05 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788420