https://www.taxtmi.com/caselaws?id=471811 Revision under Section 263 was unsustainable where the apparent share-count mismatch arose from comparing shares issued during the relevant year with cumulative shareholding, and financial records and shareholder particulars substantiated the explanation. Verification of share capital was therefore not deficient on that basis. A direction concerning share premium also could not support revision because it was absent from the show-cause notice and introduced only in the revisionary order. Although revisionary jurisdiction may extend beyond the notice's exact terms, each ground ultimately relied upon requires full notice and opportunity to respond. The original assessment could not be disturbed on either ground. en-us Fri, 11 Apr 2025 00:00:00 +0530 Sat, 19 Sep 2026 08:22:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471811 Revision under Section 263 was unsustainable where the apparent share-count mismatch arose from comparing shares issued during the relevant year with cumulative shareholding, and financial records and shareholder particulars substantiated the explanation. Verification of share capital was therefore not deficient on that basis. A direction concerning share premium also could not support revision because it was absent from the show-cause notice and introduced only in the revisionary order. Although revisionary jurisdiction may extend beyond the notice's exact terms, each ground ultimately relied upon requires full notice and opportunity to respond. The original assessment could not be disturbed on either ground. Case-Laws Income Tax Fri, 11 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471811