Section 263 Revision order cannot be passed on ground not forming part of CIT Notice

PCIT Vs Universal Music India Pvt. Ltd. (Bombay High Court)

Notice under Section 263 was issued by CIT on two issues, namely, (a) disallowance of Fringe Benefit Tax (FBT) paid of Rs.10,72,532/- included in miscellaneous expenses and not allowed by the Assessing Officer and (b) provision of Rs.1,40,98,685/- in respect of slow moving and absolete inventories. The CIT directed Assessing Officer by an Order dated 20^th March, 2013 to make enquiry and examine the two issues and a third issue being particulars of payment

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