PCIT exercising suo motu revisional power cannot travel beyond scope of limited scrutiny in original order

PCIT Vs Shark Mines and Minerals Pvt. Ltd. (Orissa High Court) Orissa High Court held that while exercising suo motu revisional power u/s. 263 of the Act, the CIT cannot travel beyond the scope of the issues which form part of the ‘limited scrutiny’ in the original Assessment Order. Facts- The original assessment in the case of the Assessee came to be completed u/s. 143(3) by the AO by the Assessment Order dated 23rd November, 2016 in the ‘limited scrutiny’ category where the issue was “excess liability shown and disallowance u/s. 40A(3) of the Act.” When the Pr. CIT decided to inv...