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Assessee has raised the ground that on the facts and in the circumstances of thecaseand in law, the CIT erred in exercising jurisdiction under section 263 on the basis of issues/reasons which were not referred in the show cause notice issued by the CIT to the Appellant and without giving the Appellant the opportunity to controvert the same.

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Sec. 263 of Income Tax Act, 1961— Revision —NIIT FOUNDATION vs. CIT.[2020] 25 ITCD Online 086 (ITAT-DELHI)

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