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...
Income Tax : Ahmedabad ITAT quashes reassessments based on ACB report, ruling the AO lacked independent "reason to believe" and only used borro...
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...
Income Tax : An analysis of Sections 263 and 264 of the Income-tax Act, 1961. It details the conditions, scope, and judicial precedents for the...
Income Tax : Karnataka High Court allows PCIT's appeal, upholding a Section 263 revision for non-disallowance of commission payments without TD...
Income Tax : National Chamber of Industries & Commerce, U.P has made a representation against Indiscriminate notices by the Income Tax Depa...
Income Tax : KSCAA has made a Representation on Challenges in Income Tax Related to Rectification Proceedings, Order Giving Effect, Delay in P...
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...
Income Tax : ITAT held that the AO’s verification of seized material, statements, and bank records constituted proper enquiry. Key takeaway:Â...
Income Tax : Since the CIT(E) had already accepted the assessed income by issuing Form 4 under the DTVSV Scheme, initiating revision later was ...
Income Tax : ITAT Ahmedabad held that the AO had conducted detailed enquiries into long-term capital gains from penny stock transactions, and t...
Income Tax : ITAT Jaipur held that addition towards unaccounted commission based on seized digital sheet without corroborative evidence is not ...
Income Tax : The Tribunal ruled that once an assessment under Section 153A is approved under Section 153D, it cannot be revised under Section 2...
ITAT held that the AO’s verification of seized material, statements, and bank records constituted proper enquiry. Key takeaway: Section 263 cannot be invoked merely because the PCIT prefers a different view.
Since the CIT(E) had already accepted the assessed income by issuing Form 4 under the DTVSV Scheme, initiating revision later was held impermissible. Key takeaway: once settled under DTVSV, the assessment cannot be reopened through Section 263.
ITAT Ahmedabad held that the AO had conducted detailed enquiries into long-term capital gains from penny stock transactions, and the PCIT’s revision under section 263 was based only on an audit objection. Since the AO’s view was plausible and well-supported, the revisional action was unsustainable and quashed.
ITAT Jaipur held that addition towards unaccounted commission based on seized digital sheet without corroborative evidence is not sustainable. Accordingly, addition is deleted and said ground raised by assessee is allowed.
The Tribunal ruled that once an assessment under Section 153A is approved under Section 153D, it cannot be revised under Section 263. This reinforces limits on PCIT’s revisional powers.
The Tribunal held that investment in agricultural land in a spouse’s name qualifies for deduction under Section 54B, following Rajasthan High Court precedent.
The Supreme Court held that revision under Section 263 requires both error and prejudice to revenue. In this case, depreciation claimed by a loss-making entity was tax-neutral, so revision was invalid.
ITAT Delhi dismissed the appeal challenging PCIT’s exercise of jurisdiction under Section 263, holding that the Commissioner can revise orders even when the matter is pending before CIT(A). Key takeaway: jurisdiction under Sec. 263 extends to unresolved appeals.
ITAT Mumbai held that revisionary proceeding under section 263 of the Income Tax Act is liable to be quashed since AO took one of the possible views while allowing claim of deduction under section 54F. Accordingly, order is quashed and appeal is allowed.
ITAT Mumbai held that the Assessing Officer made detailed enquiries before allowing ESOP expenditure, invalidating the PCIT’s revision under section 263.
