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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


Buyback through High Court approved scheme needs verification of NAV valuation u/r 11UA: Matter remitted

December 23, 2025 492 Views 0 comment Print

ITAT Chennai held that the matter of buyback through High Court approved scheme of arrangment remitted back for verification of NAV valuation under rule 11UA and also to analyize applicability of section 115QA. Accordingly, appeal restored back.

Section 144C Can’t Extend Limitation: TP Assessment Quashed as Time-Barred

December 22, 2025 486 Views 0 comment Print

The dispute centered on whether DRP directions allow completion of assessment beyond statutory time limits. The Tribunal clarified that section 144C does not create an independent limitation period. Procedural timelines cannot defeat the mandatory bar under section 153.

Section 263 Revision Upheld as AO Taxed Only TDS Credit Instead of Undisclosed Commission

December 22, 2025 201 Views 0 comment Print

The ITAT held that taxing only TDS credit, while leaving the underlying undisclosed commission untaxed, is a patent error. Section 263 revision was rightly invoked to protect revenue.

PCIT Cannot Invoke Section 263 When AO Took a Plausible View After Verification of Goodwill Claim

December 22, 2025 225 Views 0 comment Print

The ITAT held that revision under Section 263 was invalid because the Assessing Officer had conducted detailed enquiries into goodwill depreciation. A plausible view taken after scrutiny cannot be branded as erroneous.

Section 263 Revision Quashed for Substituting PCIT’s Opinion Over AO’s Due Inquiry

December 22, 2025 219 Views 0 comment Print

The issue was whether revision under section 263 could be invoked to deny 80P deduction on interest from co-operative bank deposits. The ITAT held that such revision is invalid when the AO has taken a legally settled and permissible view.

Earlier Section 263 Action Cannot Justify Fresh 153C Assessment

December 22, 2025 300 Views 0 comment Print

The Revenue made additions on alleged penny-stock transactions under section 68. The ITAT held that once section 153C jurisdiction itself fails, the additions automatically fall without examination on merits.

Section 263 Invoked for Failure to Verify Source of Cash Deposits

December 21, 2025 318 Views 0 comment Print

The Tribunal upheld revision after finding that the Assessing Officer accepted explanations without proper verification. The ruling stresses that insufficient enquiry can justify action under Section 263.

Chennai ITAT Quashes Revision Section 263 for No Error in AO’s Assessment

December 21, 2025 609 Views 0 comment Print

Chennai ITAT set aside the PCIT’s revision order under Section 263, confirming that when the AO adopts a plausible view and conducts proper scrutiny, revision is unwarranted.

Section 263 Quashed: CIT Cannot Revisit Issues Already Examined by AO

December 19, 2025 243 Views 0 comment Print

The Tribunal held that once the Assessing Officer has examined and accepted the source of property investment, the Commissioner of Income Tax (Exemption) cannot reopen the issue under section 263. The ruling emphasizes finality of AO’s findings.

PCIT Cannot Invoke Section 263 for Mere Technical Lapse

December 19, 2025 315 Views 0 comment Print

The Tribunal reaffirmed that revision cannot be exercised merely because the PCIT holds a different view. When the Assessing Officer’s view is plausible and based on enquiry, the assessment cannot be branded as erroneous or prejudicial.

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