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 ...
The Tribunal held that revision cannot be based on alleged lack of enquiry when detailed verification was already done. A mere change of opinion does not justify section 263 action.
The revision questioned deduction on interest income allowed under section 80P. The Tribunal held that where the AO adopts a legally plausible view after enquiry, section 263 cannot be invoked.
The Tribunal observed that the purpose of revision is to protect revenue interests. When no tax demand arises in consequential proceedings, the revision order no longer calls for adjudication.
The tribunal ruled that section 263 cannot be invoked merely because the Commissioner believes further enquiry was possible. Unless the order is unsustainable in law, revision on alleged inadequate enquiry is impermissible.
The tribunal held that land registered in an individual’s name but fully paid by a society amounts to receipt of property without consideration. Such benefit is taxable as income under section 56(2)(vii).
The PCIT sought to revisit claims already scrutinized and partly disallowed. The Tribunal ruled this to be a change of opinion and invalid. Revision demands clear error and prejudice, not reappraisal.
The ITAT held that earning significant exempt dividend income necessarily involves indirect administrative expenses. In the absence of separate books, the AO rightly applied Rule 8D to compute disallowance.
The AO taxed entire bank credits despite accepting the assessee as an entry operator. ITAT ruled that fund rotations cannot be treated as unexplained once the nature of business is admitted.
The Tribunal ruled that section 263 cannot be invoked merely because no addition was made during reassessment. When the AO conducts proper enquiries and accepts the explanation, revision fails for lack of error and prejudice.
The issue concerned excess interest deduction claimed by inflating EBITDA through Ind-AS fair-value adjustments. ITAT held that the AO made no enquiry on this critical computation, making the assessment erroneous.
