Show cause notice to assessee issued by CIT u/s 263

IT : Where show cause notice to assessee issued by CIT u/s 263 set out grounds for revision as 'inadmissible deductions', revision order cannot be made by CIT on the grounds of 'lack of proper inquiries' by AO. A revision order can only be, made on the ground on which assessee has been given a reasonable opportunity of being heard. It is not open to the CIT to set out one reason for revising the order in show cause notice but actually revise the order on some other ground
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[2015] 53 taxmann.com 402 (Delhi - Trib.)
IN THE ITAT DELHI BENCH 'A'
B.S. Sangwan
v.
Income-tax Officer, Ward -2, Sonipat
PRAMOD KUMAR, ACCOUNTANT MEMBER
AND C.M. GARG, JUDICIAL MEMBER
IT APPEAL NO. 2680 (DELHI) OF 2011
[ASSESSMENT YEAR 2007-08]
JANUARY  21, 2015
Naveen C. Gupta for the Appellant. A. Mishra for the Respondent.