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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 765 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 2394 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 708 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 828 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 972 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 10689 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 8235 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 7326 Views 0 comment Print


Latest Judiciary


Assessment Order Passed on Deceased Person Is Nullity in Law: ITAT Ahmedabad

Income Tax : ITAT held an assessment passed after the taxpayer's death was invalid in law, quashed the order, and treated all remaining issues ...

July 4, 2026 162 Views 0 comment Print

ITAT Deletes Additions as AO Made No Independent Inquiry Beyond ACB Information

Income Tax : ITAT deleted additions after finding the AO relied only on ACB information without independent inquiry or supporting evidence. ITA...

July 2, 2026 138 Views 0 comment Print

Loan to Non-Shareholder Company Not Taxable as Deemed Dividend

Income Tax : ITAT Kolkata held that a loan received by a company that was not a shareholder of the lender could not be taxed as deemed dividend...

July 1, 2026 456 Views 0 comment Print

Bombay HC Rejects Section 263 Revision as AO Conducted Necessary Inquiry

Income Tax : The Court held that Section 263 could not be invoked where the AO had made inquiries and accepted the assessee's explanation....

June 30, 2026 171 Views 0 comment Print

Section 263 Revision Invalid if CIT Failed to Show Assessment Was Erroneous

Income Tax : The Court held that Section 263 could not be invoked where the AO had raised queries, examined replies and completed the assessmen...

June 30, 2026 135 Views 0 comment Print


Section 263 Revision Invalid as PCIT Acted Without Independent Application of Mind

April 3, 2026 660 Views 0 comment Print

The court held that revision under section 263 requires independent satisfaction by the PCIT. Acting merely on the Assessing Officer’s view renders the revision order invalid.

Section 54F Relief Allowed in Reassessment: ITAT Treats JDA Flats as Investment

April 2, 2026 1128 Views 0 comment Print

ITAT ruled that deduction under Section 54F can be raised during reassessment if it relates to the income under scrutiny. The case clarifies that reassessment scope includes such connected claims.

Section 263 Revision Quashed Due to Pending Appeal on Same Issue Before CIT(A)

April 1, 2026 861 Views 0 comment Print

The ITAT held that the PCIT cannot invoke revisionary powers when the same issue is already pending before the appellate authority. The case involved share transaction additions treated as penny stock. 

Reassessment Notice Quashed Due to Extinguishment of Tax Liabilities Under Approved Resolution Plan

April 1, 2026 801 Views 0 comment Print

The High Court held that once a resolution plan under IBC extinguishes prior tax liabilities, reassessment cannot be initiated. The notice under Section 148 was set aside. The ruling confirms that extinguished claims cannot be revived through reassessment.

Section 263 Invalid as AO Conducted Inquiry on CSR Deduction Claim

March 31, 2026 399 Views 0 comment Print

ITAT held that revision under Section 263 cannot be invoked when the Assessing Officer has already examined the issue. The ruling emphasizes that mere disagreement with enquiry results does not justify revision.

Section 263 Cannot Override DRP: ITAT Mumbai Quashes Revision

March 30, 2026 387 Views 0 comment Print

The Tribunal held that an assessment order passed in compliance with DRP directions cannot be revised under Section 263. It clarified that such orders are not erroneous as the Assessing Officer is bound by DRP’s binding instructions.

Missed DRP timeline kills TP addition; ₹288 Cr share capital upheld

March 27, 2026 669 Views 0 comment Print

The Tribunal held that transfer pricing adjustment cannot survive without a final assessment order post-DRP directions. Repeating such addition in a Section 263 order was held invalid.

Section 263 Invalid as Presumptive Section 44AD Taxation Requires No Books

March 27, 2026 891 Views 0 comment Print

The issue involved revision of assessment where income was declared under Section 44AD. The Tribunal held that absence of books makes Section 68 inapplicable. The takeaway is that revision cannot be based on lack of records not required by law.

Revision Under Section 263 Invalid as AO Conducted Adequate Inquiry: ITAT Mumbai

March 24, 2026 468 Views 0 comment Print

The issue was whether the assessment order could be revised for lack of inquiry. The Tribunal held that since the Assessing Officer had examined the issues and taken a view, revision under Section 263 was not justified.

Mere Receipt of Salary in India Does Not Make It Taxable for Non-Resident: ITAT Mumbai

March 24, 2026 759 Views 0 comment Print

The Tribunal examined whether foreign assignment salary credited in India is taxable. It held that salary for services rendered outside India is not taxable, even if received in India.

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