Matter which was not subject matter of limited scrutiny cannot be raised in revisionary proceedings

Longia Engineers Vs PCIT (ITAT Chandigarh)

ITAT held that matter relating to wages/labour expenses which was not subject matter of limited scrutiny cannot be raised in revisionary proceedings u/s 263 for the first time. It is now a settled position as held by the various Benches of the Tribunal that the matter which was not subject matter of limited scrutiny cannot be raised in revisionary proceedings u/s 263 and thereby enlarging the scope of limited scrutiny and broadening the scope of jurisdiction that was origina

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