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section 263

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CIT(A) cannot enhance income on issues not examined by AO: ITAT Mumbai

Income Tax : The Tribunal held that CIT(A) cannot enhance income under Section 251 on matters not considered by the Assessing Officer during as...

May 10, 2026 579 Views 0 comment Print

Adv. Mukul Rohatgi Case: Section 263 Revision Invalid as AO Had Conducted Proper Inquiry

Income Tax : The ITAT held that revisional powers under Section 263 cannot be exercised when the Assessing Officer has already examined the iss...

March 7, 2026 2250 Views 0 comment Print

ITAT Quashes PCIT’s Revision as AO’s View on Survey Income Was Plausible & Verified

Income Tax : ITAT quashed PCIT’s Section 263 order, holding AO’s treatment of survey income as business income valid and not erroneous or p...

November 9, 2025 648 Views 0 comment Print

Reopening on Borrowed Belief from ACB Quashed – Tribunal holds 147 invalid & 263 unsustainable

Income Tax : Ahmedabad ITAT quashes reassessments based on ACB report, ruling the AO lacked independent "reason to believe" and only used borro...

October 26, 2025 780 Views 0 comment Print

ITAT Pune Upholds order u/s 263 – Unverified Advances Towards Property Purchase

Income Tax : ITAT Pune upholds PCIT's order u/s 263, setting aside an assessment for failure to verify ₹82.64 crore in advances for property...

October 4, 2025 918 Views 0 comment Print


Latest News


Indiscriminate notices by Income Tax Department without allowing reasonable time

Income Tax : National Chamber of Industries & Commerce, U.P has made a representation against Indiscriminate notices by the Income Tax Depa...

March 29, 2022 10668 Views 0 comment Print

Representation – Challenges in Certain Income Tax Provisions

Income Tax : KSCAA has made a Representation on Challenges in Income Tax Related to Rectification Proceedings, Order Giving Effect, Delay in P...

March 15, 2022 8199 Views 2 comments Print

No Reopening of Assessment to be made on Audit Objections: Committee Recommends

Income Tax : One of the key sources of dispute is the existing arrangement for follow up on audit objections by Internal Audit Party and the Re...

January 20, 2016 7290 Views 0 comment Print


Latest Judiciary


DVO Valuation Alone Cannot Justify Section 69 Addition Without Extra Payment Proof: ITAT Amritsar

Income Tax : The ITAT Amritsar held that a valuation report by itself cannot justify addition under Section 69 without evidence of extra paymen...

May 22, 2026 93 Views 0 comment Print

ITAT Allows Higher BOT Road Amortization Due to Early Termination of Concession Agreement

Income Tax : ITAT Mumbai held that amortization of BOT road project expenditure must be computed based on the actual concession period and not ...

May 21, 2026 90 Views 0 comment Print

Section 263 Proceedings Quashed as AO’s Order Was Not Erroneous in Jewellery Case

Income Tax : The Tribunal held that the reassessment order could not be revised under Section 263 since the conditions for treating jewellery e...

May 20, 2026 129 Views 0 comment Print

ITAT Quashes TP Assessment Orders as Consequential Orders Were Passed Beyond Limitation Period

Income Tax : ITAT Hyderabad held that assessment orders passed pursuant to earlier remand directions were barred by limitation under Section 15...

May 19, 2026 147 Views 0 comment Print

AO Cannot Travel Beyond Scope of Section 263 Directions – ITAT Upholds Deletion of Fresh Additions

Income Tax : Delhi ITAT held that an Assessing Officer cannot make additions beyond the specific issues remanded by the Principal Commissioner ...

May 19, 2026 165 Views 0 comment Print


Latest Posts in section 263

DVO Valuation Alone Cannot Justify Section 69 Addition Without Extra Payment Proof: ITAT Amritsar

May 22, 2026 93 Views 0 comment Print

The ITAT Amritsar held that a valuation report by itself cannot justify addition under Section 69 without evidence of extra payment. The Tribunal deleted the addition after finding no proof of on-money beyond the registered sale deed value.

ITAT Allows Higher BOT Road Amortization Due to Early Termination of Concession Agreement

May 21, 2026 90 Views 0 comment Print

ITAT Mumbai held that amortization of BOT road project expenditure must be computed based on the actual concession period and not on an unimplemented extension proposal. The Tribunal directed recomputation after recognizing termination of the agreement before 2024.

Section 263 Proceedings Quashed as AO’s Order Was Not Erroneous in Jewellery Case

May 20, 2026 129 Views 0 comment Print

The Tribunal held that the reassessment order could not be revised under Section 263 since the conditions for treating jewellery expenses as perquisite under Section 17(2) were not satisfied. The appeal of the assessee was allowed.

ITAT Quashes TP Assessment Orders as Consequential Orders Were Passed Beyond Limitation Period

May 19, 2026 147 Views 0 comment Print

ITAT Hyderabad held that assessment orders passed pursuant to earlier remand directions were barred by limitation under Section 153. The Tribunal set aside all consequential transfer pricing assessment orders dated 06.12.2024.

AO Cannot Travel Beyond Scope of Section 263 Directions – ITAT Upholds Deletion of Fresh Additions

May 19, 2026 165 Views 0 comment Print

Delhi ITAT held that an Assessing Officer cannot make additions beyond the specific issues remanded by the Principal Commissioner under Section 263. Fresh additions unrelated to the revision directions were therefore rightly deleted.

ITAT Slams ‘Sweeping’ 263 Revision – PCIT Cannot Order Fishing Enquiries After Detailed Scrutiny by AO

May 19, 2026 150 Views 0 comment Print

Delhi ITAT held that revision under Section 263 cannot be invoked merely because the PCIT desires deeper investigation after detailed assessment scrutiny. The Tribunal found that the AO had examined all major issues through extensive enquiries and documentation.

ITAT Hyderabad Upholds Sec 263 Revision Over Inadequate Capital Gains Inquiry

May 18, 2026 210 Views 0 comment Print

The Tribunal held that the AO failed to properly verify the genuineness of a cancelled property sale transaction before accepting the assessee’s claim of no capital gains. It ruled that lack of inquiry justified revision under Section 263.

Chennai ITAT Quashes Reassessment – Notice u/s 148 Beyond 3 Years Needs PCCIT Approval, Not PCIT Approval

May 18, 2026 210 Views 0 comment Print

Chennai ITAT held that reassessment notices issued after three years must comply strictly with Section 151(ii) approval requirements. Failure to obtain sanction from the proper authority vitiated the entire reassessment proceedings.

Calcutta HC Upholds Section 263 Revision as AO Failed to Examine Allocation of Head Office Expenses

May 17, 2026 333 Views 0 comment Print

Calcutta High Court held that failure to investigate allocation of common head office expenses to eligible units rendered assessment erroneous and prejudicial to Revenue interests.

ITAT Quashes Section 263 Revision as AO Conducted Detailed Inquiry into Agricultural Income

May 15, 2026 255 Views 0 comment Print

ITAT Rajkot held that revision under section 263 was not sustainable where the Assessing Officer had already conducted extensive verification of agricultural income and expenses. The Tribunal observed that detailed notices, documentary evidence, and independent inquiries were part of the original assessment proceedings.

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