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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 135 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


Revision power u/s 263 cannot be invoked if enquiry conducted by AO

December 14, 2022 2583 Views 1 comment Print

ITAT Pune held that if there was enquiry conducted by the AO even if the enquiry in inadequate there will be no occasion to the Commissioner to exercise the power of revision u/s 263 of the Income Tax Act.

Section 263 cannot be invoked to correct section under which penalty is leviable

December 14, 2022 5784 Views 0 comment Print

ITAT held that invocation of provision of 263 to correct section under which penalty is leviable or not is beyond the power vested under section 263 of Income Tax Act,

Order passed u/s 263 invalid in absence of DIN

December 12, 2022 1464 Views 0 comment Print

ITAT Bangalore held that order passed under section 263 of the Income Tax Act is invalid as the same does not have any Document Identification Number.

Income Tax exemption claim allowed without examination – Section 263 revision order valid

December 12, 2022 435 Views 0 comment Print

L&T Infra Debt Fund Limited Vs CIT (Exemption) (ITAT Mumbai) In the instant case, we notice that the AO did not examine the exemption claimed u/s 10(47) of the Act, meaning thereby, the assessment order has been passed by the AO without application of mind. The exemption so allowed without examining the claim would be […]

interest income earned by co-op society from co-op banks qualifies for deduction u/s 80(P)(2)(d)

December 7, 2022 3966 Views 0 comment Print

Lokmangal Nagri Sahakari Path Sanstha Maryadit Vs PCIT (ITAT Pune) In the present case, we find that admittedly the interest income was earned from the cooperative banks, the cooperative bank is also a specie of cooperative society, therefore, the interest income earned by the cooperative society from the cooperative banks qualifies for deduction u/s 80(P)(2)(d) […]

Section 263 not invocable if assessment order is not erroneous or prejudicial to interests of revenue

December 7, 2022 1566 Views 0 comment Print

Shri Arunoday Multi State Cooperative Credit Society Ltd. Vs PCIT (ITAT Pune) The issue in the present appeal relates to the validity of assumption of jurisdiction u/s 263 by the ld. PCIT. The Parliament had conferred the power of revision on the Commissioner of Income Tax u/s 263 of the Act in case the assessment […]

Section 263 revision not valid for duly explained cash payment exceeding threshold limit to AO with documents

December 6, 2022 840 Views 0 comment Print

PCIT Vs Shukla Dairy Pvt. Ltd. (Gujarat High Court) We note that during the assessment proceedings, assesses had submitted before assessing officer (AO), the cash payment register and explained each of the item of proposed addition as per show cause notice of assessing officer. The cash payment register, which is placed at paper book page […]

Revision proceedings cannot be sustained if assessee opted to settle dispute under DTVSV Scheme

November 24, 2022 2562 Views 0 comment Print

In present facts of the case, the ITAT observed that proceedings under Section 263 of Income Tax Act, 1961 cannot be sustained if the tax payer had opted to settle the dispute under the Direct Tax Vivad Se Vishwas Act, 2020.

PCIT cannot substitute his view with view of AO & direct AO to make assessment in a particular manner

November 24, 2022 1182 Views 0 comment Print

Komara Gounder Chinnusamy Vs ITO (ITAT Chennai) The PCIT has revised assessment order passed by the AO u/s.143(3) r.w.s.147 of the Act, on the issue of trade discount received by the assessee from M/s. SKM Animal Feeds and Foods (India) Pvt. Ltd., amounting to Rs.23,16,261/-. According to the PCIT, although, the assessee has received trade […]

Invocation of power u/s 263 unjustified as order neither erroneous nor prejudicial to interest of revenue

November 23, 2022 1323 Views 0 comment Print

ITAT Bangalore held that revisionary power u/s 263 cannot be invoked when the order passed by AO is neither erroneous nor prejudicial to the interest of revenue.

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