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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


ITAT Pune: ₹1.62 Cr u/s 68 Deleted — No “Source of Source” Needed Pre-01.04.2023

December 5, 2025 1794 Views 0 comment Print

Explains how ITAT Pune held that unsecured loans prior to 01.04.2023 do not require proving the lender’s source of funds, leading to deletion of a ₹1.62 crore addition.

Section 148 Notice Without Jurisdiction Renders 263 Unsustainable

December 3, 2025 684 Views 0 comment Print

ITAT Ahmedabad held that a section 263 revision cannot proceed if the AO issuing section 148 notice lacks territorial jurisdiction, emphasizing the need to first decide jurisdictional validity.

CIT(A) Cannot Hide Behind PCIT’s 263 Order – Independent Application of Mind Mandatory

December 3, 2025 381 Views 0 comment Print

ITAT Jabalpur held that CIT(A) cannot blindly follow PCIT directions under section 263. Appellate authorities must independently consider evidence and objections before confirming additions.

Banks Can Compute 36(1)(viia) on Total Income Including Capital Gains: ITAT Ahmedabad

December 3, 2025 456 Views 0 comment Print

ITAT Ahmedabad held that banks can claim deductions for provisions for bad debts on total income, including capital gains, rejecting the CIT’s restriction to business income.

No Inquiry, No Jurisdiction: PCIT Revision Under Section 263 Invalid

December 3, 2025 330 Views 0 comment Print

ITAT held that Section 263 requires the PCIT to conduct independent inquiry before declaring an order erroneous. Since the PCIT relied only on assumptions of inadequate inquiry, the revision was invalid.

Revision Barred After VSV Settlement: ITAT Rules Section 263 Cannot Reopen Concluded Disputes

December 3, 2025 498 Views 0 comment Print

Holds that once a tax dispute is settled under the Vivad Se Vishwas Act, Section 263 revision cannot be invoked. Confirms that VSV grants finality and bars reopening of settled issues.

Land Acquisition Act Section 28 Interest is Not ‘Interest’: Tribunal Deletes Entire Addition as Capital Receipt

December 3, 2025 1059 Views 0 comment Print

Tribunal holds that Section 28 interest forms part of compensation for compulsory acquisition and cannot be taxed as income from other sources. Confirms exemption under Section 10(37).

Section 263 Order Quashed: Null Assessment Cannot Be Revised Under IBC

December 2, 2025 378 Views 0 comment Print

The Tribunal held that once the High Court had already quashed the original assessment for violating the IBC resolution plan, the PCIT’s section 263 revision could not survive. Since a revision must rest on a valid assessment order, the entire 263 action became void. The appeals were allowed and the revision orders were cancelled.

Section 263 Upheld as AO Failed to Verify TDS Rates & Delayed PF/ESI Payments

December 1, 2025 417 Views 0 comment Print

The Tribunal held that the original assessment was not erroneous or prejudicial except for TDS verification and PF/ESI disallowance. The assessee’s claim under Section 10AA was rejected. Compliance with statutory deductions is critical for valid assessments.

Nominal & Associate Members Do Not Invalidate Section 80P Deductions: ITAT Panaji

December 1, 2025 675 Views 0 comment Print

Tribunal rules that Souharda societies registered under state law qualify as cooperative societies under section 2(19), allowing 80P(2)(a)(i) and 80P(2)(d) deductions. Revenue’s appeal dismissed.

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