S. 263 Revision order based on grounds not shown in show cause notice is not valid

Objection raised by the CIT in the show-cause notice issued under s. 263 of the Act was in relation to non-deduction of tax at source out of certain payments made by the assessee and the invoking of provisions of s. 40(a)(ia) of the Act. However, in the ultimate analysis, the CIT has directed the AO to recompute the income in the hands of the assessee by applying suitable net profit rate. Such direction of the CIT in exercise of power under s. 263 of the Act is not warranted and the same is set aside. The second direction of the CIT under s. 263 of the Act for initiation of penalty proceedings...