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 : ITAT held an assessment passed after the taxpayer's death was invalid in law, quashed the order, and treated all remaining issues ...
Income Tax : ITAT deleted additions after finding the AO relied only on ACB information without independent inquiry or supporting evidence. ITA...
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...
Income Tax : The Court held that Section 263 could not be invoked where the AO had made inquiries and accepted the assessee's explanation....
Income Tax : The Court held that Section 263 could not be invoked where the AO had raised queries, examined replies and completed the assessmen...
The Tribunal ruled that failure to verify discrepancies in quantitative stock details justified revisionary action. Mere calling of documents without proper examination invites Section 263 proceedings.
The PCIT questioned deduction under Section 80JJAA and CSR expenses but failed to record specific findings. The Tribunal held that absence of independent verification and reasoning renders the Section 263 order invalid.
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.
