Passing of revisionary order u/s 263 without issuance of notice on subject matter is unjustified

Inject Care Parenterals Pvt. Ltd Vs PCIT (ITAT Surat) ITAT Surat restored the matter back to the file of Pr. CIT as revisionary order under section 263 of the Income Tax Act cannot be passed without issuance of show cause notice on the subject matter. Such revisionary order is against the principal of natural justice. Facts- The case of the assessee was selected for scrutiny and assessment was completed u/s 143(3) r.w.s. 143A/143(3)(b). Thereafter, revised the same by Pr.CIT by exercising jurisdiction u/s 263 with regard to the issue of employee’s contribution not deposited before due date. ...