https://www.taxtmi.com/caselaws?id=795846 Prior notice is mandatory before the Commissioner (Appeals) enhances an assessment. Section 251(2) requires a reasonable opportunity to show cause against the specific proposed enhancement; general scrutiny of ledger accounts or participation in appellate proceedings does not replace explicit notice. Without such notice, the assessee is denied the statutory opportunity to contest the enhanced disallowance. The stated conclusion is that enhancement without prior notice is impermissible. en-us Thu, 23 Jul 2026 00:00:00 +0530 Tue, 28 Jul 2026 08:30:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795846 Prior notice is mandatory before the Commissioner (Appeals) enhances an assessment. Section 251(2) requires a reasonable opportunity to show cause against the specific proposed enhancement; general scrutiny of ledger accounts or participation in appellate proceedings does not replace explicit notice. Without such notice, the assessee is denied the statutory opportunity to contest the enhanced disallowance. The stated conclusion is that enhancement without prior notice is impermissible. Case-Laws Income Tax Thu, 23 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795846