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 Tribunal held that amounts paid directly to a confirming party did not accrue to the seller and could not be treated as capital gains. The Section 263 revision was invalidated because the assessment was neither erroneous nor prejudicial to the Revenue.
Reopening notice under Section 148 was held invalid as the AO ignored co-purchasers’ contributions and granted mechanical approval under Section 151 without application of mind. The Tribunal ruled the reassessment and associated additions null and void.
ITAT held that Section 263 cannot be invoked when the AO has already examined the issues and applied his mind. Key takeaway: Mere preference for deeper enquiry does not make an assessment erroneous.
The ITAT Mumbai held that Section 263 cannot be invoked when the Assessing Officer has taken a permissible view after inquiry. Revision order quashed, upholding reassessment.
The PCIT held the AO’s assessment under section 143(3) as erroneous and prejudicial to Revenue, directing fresh verification of various deductions. The assessee argued all claims were correctly examined, questioning the jurisdiction of section 263.
ITAT held that section 263 cannot be invoked unless the PCIT pinpoints an actual error in the AO’s order; since no specific mistake was shown, the revision was invalid.
The Tribunal held that the AO’s omission to verify whether the land sold fell within municipal limits made the assessment erroneous and prejudicial to the revenue, justifying Section 263 revision.
ITAT held that the AO’s verification of seized material, statements, and bank records constituted proper enquiry. Key takeaway: Section 263 cannot be invoked merely because the PCIT prefers a different view.
Since the CIT(E) had already accepted the assessed income by issuing Form 4 under the DTVSV Scheme, initiating revision later was held impermissible. Key takeaway: once settled under DTVSV, the assessment cannot be reopened through Section 263.
ITAT Ahmedabad held that the AO had conducted detailed enquiries into long-term capital gains from penny stock transactions, and the PCIT’s revision under section 263 was based only on an audit objection. Since the AO’s view was plausible and well-supported, the revisional action was unsustainable and quashed.
