Revision Invalid Where New Issues Added Beyond 263 Notice: ITAT Mumbai

Perfect Filaments Ltd. Vs PCIT (ITAT Mumbai)

Revision Invalid Where New Issues Added Beyond 263 Notice – ITAT Strikes Down PCIT’s Expansion of 263 Without Notice

Assessee, engaged in manufacturing dyed polyester yarn, filed return declaring ₹16.91 crores income. AO completed scrutiny assessment on 02.09.2022 accepting return. PCIT issued 263 notice on 03.03.2025 alleging three errors:

(a) wrong claim of ₹92.01 lakhs as deduction being interest on delayed TDS;

(b) omission to disall

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