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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 132 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


Detailed U/s 153C Enquiry Bars PCIT from Revising Completed Assessment

December 29, 2025 243 Views 0 comment Print

The Tribunal reaffirmed that revision is impermissible when the Assessing Officer adopts a reasonable view after due enquiry. Section 263 cannot be invoked merely because the PCIT prefers another line of investigation.

PCIT Can’t Convert Bogus Purchases Into U/s 69C to Apply U/s 115BBE

December 27, 2025 1008 Views 0 comment Print

The issue was whether bogus purchases disallowed under section 37(1) must be reclassified as unexplained expenditure under section 69C. ITAT held that where the source of expenditure is known, section 69C cannot be mechanically invoked.

Section 68 Proviso Not Retrospective – ITAT Quashes Huge Share Capital Addition

December 27, 2025 687 Views 0 comment Print

The ITAT held that the proviso to Section 68 requiring proof of source of source applies only from AY 2013–14. Since the year involved was AY 2008–09, the ₹32.04 crore share capital addition was deleted as legally unsustainable.

Mechanical Invocation of Section 263 at AO’s Behest Held Bad in Law

December 26, 2025 624 Views 0 comment Print

Indian City Properties Limited Vs PCIT (ITAT Kolkata) The Tribunal held that the invocation of Section 263 on the proposal of the AO is not sustainable under the Act, as the PCIT failed to independently apply his mind and record satisfaction of the twin conditions. The assessment was completed under Section 143(3) r.w.s. 144B after […]

Revision u/s. 263 for non-verification of notional interest not justified as it is taxable only on maturity

December 26, 2025 414 Views 0 comment Print

ITAT Chandigarh held that initiation of revisionary proceeding under section 263 of the Income Tax Act for non-verification of notional interest cannot be justified since notional interest is not liable to be taxed in current year but is taxable only upon maturity hence there cannot be any evasion of tax.

Section 263 Revision Quashed as AO Examined Depreciation on Goodwill: Gujarat HC

December 25, 2025 699 Views 0 comment Print

The issue was whether depreciation on goodwill arising from demerger was wrongly allowed. The Court held that since the Assessing Officer had made due enquiries and taken a plausible view, revision under Section 263 was invalid.

Section 80P(2)(d) Deduction Allowed Because Co-op Bank Is Also a Co-op Society

December 25, 2025 255 Views 0 comment Print

The issue was whether interest earned from a co-operative bank qualifies for deduction under Section 80P(2)(d). The Tribunal held that such interest is deductible, as a co-operative bank is itself a co-operative society.

Section 271D Penalty Quashed as Time-Barred in Absence of Assessment: ITAT Chennai

December 25, 2025 1350 Views 0 comment Print

The Tribunal held that penalties under Section 271D were invalid as they were imposed beyond the limitation period prescribed under Section 275(1)(c).

Simultaneous Section 80IA & 80HHC Deductions Allowed Subject to 100% Cap: Madras HC

December 25, 2025 225 Views 0 comment Print

The court held that deductions under Sections 80-IA and 80-HHC can be claimed simultaneously, subject only to an overall cap of 100% of business profits.

Section 263 Quashed Because It Was Used Only for Review of a Completed Assessment

December 23, 2025 651 Views 0 comment Print

The ITAT held that revision is invalid when invoked merely to re-examine an issue already scrutinised by the Assessing Officer.

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