Section 263: Revisional order becomes legally fragile on failure to provide opportunity of hearing to assessee

Bses Rajdhani Power Ltd. Vs. Principal CIT (Delhi High Court)

Court has repeatedly held that unlike the power of reopening an assessment under Section 147 of the Act, the power of revision under Section 263 is not contingent on the giving of a notice to show cause. In fact, Section 263 has been understood not to require any specific show cause notice to be served on the assessee. Rather, what is required u

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