Income Tax : The Tribunal held that CIT(A) cannot enhance income under Section 251 on matters not considered by the Assessing Officer during as...
Income Tax : The ITAT held that revisional powers under Section 263 cannot be exercised when the Assessing Officer has already examined the iss...
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 : 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 : The ITAT Amritsar held that a valuation report by itself cannot justify addition under Section 69 without evidence of extra paymen...
Income Tax : ITAT Mumbai held that amortization of BOT road project expenditure must be computed based on the actual concession period and not ...
Income Tax : The Tribunal held that the reassessment order could not be revised under Section 263 since the conditions for treating jewellery e...
Income Tax : ITAT Hyderabad held that assessment orders passed pursuant to earlier remand directions were barred by limitation under Section 15...
Income Tax : Delhi ITAT held that an Assessing Officer cannot make additions beyond the specific issues remanded by the Principal Commissioner ...
ITAT ruled that reassessment made pursuant to a quashed Section 263 order has no legal basis. Subsequent additions cannot stand once the revision itself is annulled.
ITAT ruled that revisionary powers cannot be invoked on vague suspicion. Where identity, creditworthiness, and genuineness are documented and examined, Section 263 cannot be sustained.
The Tribunal held that where disallowance was accepted and taxes paid during revision under Section 263, penalty under Section 270A was not warranted. The appeal was allowed and penalty deleted.
The ITAT reaffirmed that Section 2(22)(e) cannot extend the definition of shareholder to a concern receiving the loan. The deemed dividend, if attracted, must be taxed in the hands of the substantial shareholder alone.
The Tribunal found that the investors had substantial net worth far exceeding their investments. With PAN, ITRs, bank statements, and audited financials on record, the share capital could not be treated as unexplained.
ITAT upheld revision under Section 263 after finding that the AO failed to verify the taxability of ₹669 crore received by a trust under Section 56(2)(x), rendering the assessment erroneous and prejudicial.
The Tribunal held that acceptance of returned income without examining material indicating possible unaccounted cash investment amounts to lack of inquiry. Section 263 revision was therefore lawfully sustained.
ITAT Mumbai held that disallowance made under section 14A of the Income Tax Act added to Book Profits for computing taxes under section 115JB Income Tax Act deserved to be deleted.
ITAT held that the 10% tolerance band under property valuation provisions applies retrospectively. The PCIT’s revision was set aside as it amounted to a change of opinion.
PCIT s revision under section 263 against assessee was upheld holding that AO did not properly verify the very low Section 14A disallowance despite huge exempt income and also ignored INSIGHT portal inputs about alleged accommodation entries.
