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 PCIT sought to revise the assessment for lack of arms length determination. The Tribunal ruled that the Assessing Officer cannot be faulted when the TPO did not act. The decision reinforces limits on section 263.
While an error in computation was acknowledged, prejudice to Revenue was not established. The Tribunal quashed the revision for lack of both ingredients. The ruling clarifies strict thresholds for invoking section 263.
The Tribunal held that interest from bank fixed deposits lacked a direct nexus with credit facilities. Deduction under Section 80P was denied as investment income dominated.
ITAT Chennai held that loss on sale of shares must be treated as long-term capital loss. Wrong accounting classification cannot convert it into a disallowable expense.
The Tribunal ruled that registration cannot be cancelled for non-maintenance of separate books when that allegation was never put to the assessee. Authorities must specify the exact clause of specified violation relied upon.
The Tribunal found that the AO had examined land records, crop sale documents, and other evidence before making the assessment. Since due inquiry was conducted, the assessment order was neither erroneous nor prejudicial to revenue.
The case concerned denial of deduction citing dealings with associate members. The Tribunal followed Supreme Court precedent and directed the AO to verify member status and society bye-laws before deciding eligibility.
The Tribunal examined whether revision under section 263 could survive when the show-cause notice was issued to an entity that had already ceased to exist due to amalgamation. It held that proceedings against a non-existent entity are void ab initio, rendering the revision order invalid.
High Court quashed the adjustment made in the intimation under Section 143(1) disallowing deduction under Section 10B and declared the rectification order to be null and void as allowability of deduction under Section 10B was examined during regular assessment proceedings and accepted
The Tribunal held that revision under section 263 cannot introduce issues outside the original limited scrutiny mandate. The key takeaway is that the PCIT cannot widen the inquiry beyond CASS-selected parameters.
