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...
ITAT Delhi held that additions under Section 69C cannot be made if the AO exceeds the scope of directions issued under Section 263, emphasizing procedural compliance.
The tribunal held that assessments completed through the DRP mechanism remain subject to the outer time limit prescribed under section 153. The key takeaway is that section 144C does not extend or override statutory limitation periods.
The Tribunal held that limitation under Section 153 overrides the DRP timeline under Section 144C. As the assessment was completed beyond the statutory outer limit, it was quashed as invalid.
The assessee argued that revision proceedings were vitiated as they followed an audit objection. The ITAT rejected this plea, holding that audit-based information can validly trigger revision if conditions of section 263 are met.
The ITAT held that revision under Section 263 cannot be invoked merely because the PCIT disagrees with the Assessing Officer’s view. Once enquiries are made and explanations accepted, substitution of opinion is impermissible.
The ITAT held that even a small part payment through banking channels before or on the agreement date is sufficient to invoke the provisos to section 56(2)(vii)(b)(ii). Substantial payment or possession is not a statutory requirement.
ITAT held PCIT cannot revise assessment where penny stock LTCG transactions were fully examined and AO adopted a permissible view.
ITAT Mumbai ruled that a co-operative society’s deposits in co-operative banks are eligible for deduction under section 80P(2)(d), despite section 80P(4) limiting banks themselves. The decision reinforces liberal interpretation of 80P to support the co-operative sector.
The Tribunal ruled that interest from deposits with co-operative banks qualifies for deduction under section 80P(2)(d). The is that co-operative banks still meet the legal definition of a co-operative society.
PCIT invoked section 263 against an assessment under section 153C. ITAT held that without challenging statutory 153D approval, revision is unsustainable, emphasizing that 153D is a statutory safeguard.
