Revision u/s. 263 beyond specific reasons recorded for reopening unjustified: ITAT Ahmedabad

Hirenkumar Lavjibhai Kanani Vs PCIT (ITAT Ahmedabad) ITAT Ahmedabad held that the revisionary jurisdiction under section 263 cannot be exercised to widen the scope of the original assessment beyond the specific reasons recorded for reopening the assessment. Facts- The reassessment proceedings were initiated for the limited scrutiny purpose of verifying the applicability of the provisions of Section 2(22)(e) of the Act, which deals with “Deemed Dividend”. AO, after considering the submissions and explanations provided by the assessee, made an addition of Rs. 3,50,000/- to the income...