Section 263 revisional order without issuing SCN is void ab initio

Yesh Daga Vs PCIT (ITAT Jaipur) In this case, it was found that the taxpayer did not receive the Show Cause Notice (SCN) as it was not sent to their email, despite the taxpayer updating their email addresses in their Income Tax Returns (ITRs) and personal profiles on the ITBA portal. The court emphasized that under Section 282 of the Income Tax Act, 1961, notices must be communicated directly to the taxpayer and cannot be presumed delivered merely by posting on the e-portal. Due to the absence of proper notice, the revisionary action initiated under Section 263 by the Principal Commissioner of...