2008 (12) TMI 4 - HC - Income Tax

Denial of claim for deduction u/s 80-IA by Commissioner (A) - Tribunal was of the view that the ground that the assessee had not fulfilled the conditions laid down u/s 80-IA did not form part of the SCN - Tribunal held that as the said issue did not form part of the SCN and the assessee was not even confronted with it, even before the CIT, it cannot form the basis for revision of the assessment order u/s 263 – tribunal’s order require no interference – revenue’s appeal dismissed