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ITAT Ahmedabad held that revisional jurisdiction u/s. 263 of the Income Tax Act not justifiable as AO had examined the issue in the course of assessment proceeding.
ITAT Kolkata ruled that PCIT’s revision under section 263 was time-barred as it exceeded the limitation period, invalidating the assessment revision.
ITAT Ahmedabad held that assessment order passed by AO without conducting adequate inquiry is erroneous and prejudicial to the interest of revenue and hence revisionary proceeding under section 263 rightly invoked by PCIT.
ITAT Ahmedabad held that invocation of revisionary power under section 263 of the Income Tax Act sustained as AO failed to conduct proper enquiries and verifications during original assessment proceedings.
ITAT Delhi held that order under section 263 of the Income Tax Act passed on the issues for which no show cause notice has been issued is unjustifiable and hence liable to be quashed.
ITAT Ahmedabad held that disallowance under section 14A of the Income Tax Act cannot exceed exempt income. Thus, disallowance u/s. 14A restricted to the extent of exempt income.
Rajasthan High Court held that since reassessment order is distinct and different, the period of limitation for exercising powers u/s. 263 of the Income Tax Act would be the date of original assessment order. Thus, entire proceedings barred by limitation.
ITAT Ahmedabad held that non application of mind or wrong assumption of facts or incorrect application of law by the A.O. will make the order erroneous and pre-judicial to the interest of revenue. Thus, as order passed without adequate inquiry, revision u/s. 263 justified.
ITAT Mumbai held that PCIT grossly erred in assuming jurisdiction u/s. 263 of the Income Tax Act as assessment order has been framed in the name of a non-existing assessee.
ITAT Ahmedabad held that invocation of section 263 by PCIT unjustified due lack of sufficient evidence to support claim that the order is erroneous and prejudicial to the interest of revenue.
