Revisional order quashed as basis for such order was completely distinguished from grounds laid down in notice
IT : Where show-cause notice issued is on one ground and revisional order is passed on an entirely different ground, order cannot be sustained in law
IT : Merely by observing that there was reason to disallow some of expenses as capital expenditure, without pointing out specifically as to which of expenses were found by Commissioner to be of capital nature, Commissioner could not exercise power under section 263
Regards
Prarthana Jalan
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