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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 2397 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


ITAT quashes section 263 order in respect of correction of arithmetical mistake

June 24, 2022 1200 Views 0 comment Print

Explore the Kyal Agencies vs. PCIT case at ITAT Cuttack. Analysis covers sundry creditors, arithmetical mistakes, and sales discount reconciliation. Know why the revision was quashed.

Section 263: PCIT cannot comment on issues not forming part of limited scrutiny

June 24, 2022 816 Views 0 comment Print

Baljeet Yadav Vs PCIT (ITAT Jaipur) It is evident from the assessment order and impugned order that the assessee’s case was selected for scrutiny under CASS for examination of cash deposits made in the bank during the demonetarization period. It is prima facie not clear whether it was a limited scrutiny case or a detailed […]

Section 263 Revision not permissible on debatable issues

June 23, 2022 831 Views 0 comment Print

Orissa Forest Development Corporation Limited Vs PCIT (ITAT Cuttack) It is admitted by Pr. CIT that he is not going into the merits of the addition as the issue constitute a matter to be adjudicated by the appellate authority. Thus, it is clearly shows that the issue is a debatable issue and it is recognized […]

Invocation of jurisdiction under Section 147 is not alternative to Section 263

June 22, 2022 1800 Views 0 comment Print

Plaza Cable Industries Ltd Vs DCIT (ITAT Delhi) The maintainability of jurisdiction under Section 147 of the Act is central to the controversy in the instant case. On perusal of the reasons recorded under Section 148(2) of the Act qua the alleged escapement as reproduced in paragraph 6 above, it is straightaway noticed that the […]

Section 263 jurisdiction not invocable if order passed by AO not prejudicial to interest of revenue

June 22, 2022 762 Views 0 comment Print

For invoking jurisdiction u/s 263 of income tax act, the assessment order passed by assessing officer should be erroneous so far as prejudicial to interest of revenue.

Share application money – ITAT quashes Section 263 Revision proceedings

June 22, 2022 768 Views 0 comment Print

Armajaro Trading India (P) Limited Vs ITO (ITAT Cochin) In the instant case, one of the reasons for limited scrutiny was for the purpose of examining whether the share application money received by the assessee was genuine and was from disclosed sources. It is seen that the assessee had shown an amount of Rs.2,55,94,110 as […]

An order not become erroneous & prejudicial to interest of Revenue merely because it is cryptic

June 20, 2022 570 Views 0 comment Print

Merely because assessment order is cryptic one without discussing in detail nature of enquiry conducted and evidences furnished by assessee, it cannot be said that order is erroneous and prejudicial to interest of Revenue.

Revision order invalid if Original Assessment completed with adequate Inquiry & Examination

June 20, 2022 405 Views 0 comment Print

Sujit Kumar Dey Vs ACIT (ITAT Kolkata) The assumption of jurisdiction u/s 263 of the Act by ld. PCIT has been challenged before us by the assessee. Before we advert to the facts and law involved in this issue before us, let us revisit the law governing the issue before us. The assessee has challenged […]

Penny Stocks Bogus Capital Gain – Calcutta HC upheld Additions

June 15, 2022 28239 Views 0 comment Print

Calcutta High Court order on Penny stock in which  Department’s appeal in penny stock case has been allowed. The Orders of AO and CIT(A) have been restored. Reversed the order of ITAT. The Court Held that : 1. The assessees cannot take shelter under the opinion given by the experts as it is not the […]

Non-Speaking Section 263 Revisional Order not maintainable

June 5, 2022 681 Views 0 comment Print

Rajdhani Transport Company Pvt. Ltd. Vs PCIT (ITAT Amritsar) In this case Section 263 order was passed only on the basis of the non-appearance of assessee and non submission of the document during the proceeding. Section 263 is moved up by two limbs, one erroneous order and second is prejudicial to the interest of the […]

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