ITAT rules Section 40A(2)(b) issues can't justify revising assessment if not mentioned by CIT in show cause notice.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Validity of Revision u/s 263 by CIT - payments made to persons specified under Section 40A(2)(b) allowed in assessment order - there is a finding by the Tribunal, as noted earlier, that no issue was raised by the CIT in respect of particulars of payment made to persons specified under Section 40A(2)(b) of the Act and even the show cause notice is silent about that. - ITAT rightly concluded that the said ground therefore cannot form the basis for revision of assessment order under Section 263 of the Act. - HC....