Case Law Details
PCIT Vs . Universal Music India Pvt. Ltd. (Bombay High Court)
Issues
(a) Whether on the facts, in the circumstances of the case and as per law, the Hon’ble ITAT has erred in holding that in the revision proceedings the CIT cannot travel beyond the reasons given by him for revision in the show-cause notice without appreciating that the power of revision under Section 263 of the I.T. Act is not contingent on the giving of a notice to show cause ?
(b) Whether on the facts, in the circumstances of the case and as per law, the Hon’ble ITAT has erred in holding that in the revision proceedings the CIT cannot travel beyond the reasons given by him for revision in the show-cause notice without appreciating the ratio laid down by Hon’ble Supreme Court in the case of CIT vs. Amitabh Bachchan (384 ITR 200) (2016) wherein it was clearly held by the Apex Court that there is nothing in Section 263 to make the CIT confine himself to the terms of show cause notice ?
Held by High Court
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