Income Enhancement Invalid Without Show Cause Notice; Appellate Authority Must Hear Taxpayer First.

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....Power of CIT(A) for enhancement u/s 251(2) - Enhancing the assessed income by making disallowances of deferred revenue expenses - There is no material on record suggesting that the assessee was awarded the opportunity of being heard before the enhancement of income by the learned CIT(A). As such, the appellate authority cannot enhance the assessment without issuing show cause notice. - AT....