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 ITAT held that the AO’s allowance of an 80G deduction without examining the background of M/s. Aadhar Foundation was erroneous. The decision reinforces that Explanation-2 to Section 263 requires verification when there is material indicating possible bogus donations.
ITAT Hyderabad held that invocation of revisionary jurisdiction under section 263 of the Income Tax Act unsustainable since AO has taken plausible view. Accordingly, assessment order is neither erroneous nor prejudicial hence revision order quashed.
ITAT Kolkata held that an assessment under section 143(3) is invalid if the section 143(2) notice does not comply with CBDT prescribed formats. The ruling nullifies both the assessment and related revisionary proceedings.
ITAT Hyderabad held that the final assessment under section 143(3) r.w.s 144C(13) passed beyond statutory time limits is invalid. The ruling reinforces that the outer limit under section 153 cannot be extended, emphasizing strict compliance with limitation provisions.
ITAT Kolkata condoned an extraordinary delay in filing appeals, emphasizing that genuine and unavoidable reasons justify late filing, allowing the appeals to proceed for adjudication.
ITAT Pune held that the CIT(A) failed to adjudicate key legal grounds, including wrong AO jurisdiction and missing Document Identification Number. Entire order under Section 144 r.w.s. 263 was set aside for reconsideration with proper hearing.
ITAT Chennai quashed reassessment under Section 147, ruling that reopening based on a change of opinion without new material is invalid.
The Hyderabad tribunal clarified that section 144C provisions are procedural and cannot extend the statutory limitation under section 153. The AO passed the final assessment order after the permissible period, leading to quashing. The ruling strengthens the principle that statutory deadlines are paramount in tax proceedings.
The Tribunal ruled that Section 263 jurisdiction is barred under Explanation 1(c) if the matter is under appeal before CIT(A). AO’s assessment, including enquiry into statements and ledgers, was found proper. PCIT’s revision attempting to tax full Rs.1.59 Cr as bogus purchase was quashed.
Because differing judicial views existed on taxation of co-operative society interest income, the AO’s accepted position could not be termed erroneous. The Tribunal ruled that debatable issues cannot trigger section 263 revision.
