CIT Cannot Enhance Assessments by Adding New Items u/s 251; Must Use Sections 148 or 263 Instead.

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....Power of CIT for enhancement u/s 251 - those items, which were not part of the ROI, Assessment proceedings or Assessment order, cannot be considered by the ld CIT (A) for enhancement. Right course would have been to intimate ld AO to issue notice u/s 148 of the Act or to propose revision u/s 263 of the Act. - AT....