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 Tribunal ruled that section 263 cannot be invoked merely because no addition was made during reassessment. When the AO conducts proper enquiries and accepts the explanation, revision fails for lack of error and prejudice.
The issue concerned excess interest deduction claimed by inflating EBITDA through Ind-AS fair-value adjustments. ITAT held that the AO made no enquiry on this critical computation, making the assessment erroneous.
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.
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.
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.
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 […]
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.
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.
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.
The Tribunal held that penalties under Section 271D were invalid as they were imposed beyond the limitation period prescribed under Section 275(1)(c).
