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2019 (7) TMI 643 - HC - Income TaxRevision u/s 263 - notice preceding the order u/s 263 was sent to the Assessee at the wrong address - sufficient opportunity was not granted to the Assessee to oppose the notice u/s 263 - HELD THAT:- On this short ground, the ITAT has remanded the matter to the PCIT for passing a fresh order after hearing the Assessee. It is plain to this Court that the remand would not result in the PCIT coming up with new grounds for reopening the assessment under Section 263 of the Act. Those grounds have already been set out in the show cause notice issued by the PCIT. All that the PCIT has now to do is to give the Assessee a hearing and pass a fresh order on merits, obviously uninfluenced by the earlier order passed by the PCIT. If the Assessee is aggrieved by such a fresh order, it will obviously be open to the Assessee to seek further remedies in accordance with law.
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