ITAT quashes CIT (Appeals) order on suo motu enhancement of the additions citing non-issue of Show Cause Notice under Sec.251(2) procedure.
ITAT Agra has held that the CIT(A) cannot enhance income without issuing a prior show-cause notice to the assessee. In the case of Simrah Builders (AY 2018–19), the Tribunal quashed the ₹54.50 lakh enhancement as it violated Section 251(2) and principles of natural justice. The assessee’s appeal was allowed purely on this legal ground.
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