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 Mumbai ITAT held that interest received by an Indian branch from its overseas head office and branches is not taxable under the domestic law as it represents transactions with self. The Tribunal applied the principle of mutuality and dismissed the Revenue’s challenge.
The ITAT Mumbai held that the assessee’s convertible debentures lacked the liability component required for classification as Compound Financial Instruments. Consequently, they could not be treated as transition amount under Section 115JB(2C).
The Karnataka High Court held that revisional powers under Section 263 cannot be exercised where the Assessing Officer has adopted one of the possible legal views. The Commissioner’s revisional order and the Tribunal’s order were quashed.
The ITAT Mumbai held that the doctrine of merger did not bar revision under Section 263 because the applicability of Section 50C was never considered during the reassessment or appellate proceedings. It upheld the revision while directing fresh consideration of the property’s valuation through the prescribed statutory mechanism.
Delhi ITAT held that donations qualifying under Section 80G do not lose eligibility merely because they form part of Corporate Social Responsibility (CSR) expenditure.
The Chennai ITAT held that the Pr. CIT could not invoke Section 263 on matters already under consideration before the appellate authority. The ruling emphasises the statutory bar against parallel revision proceedings on the same issue.
The Tribunal upheld the disallowance of a ₹10 lakh deduction after the recipient political party informed the tax authorities that it had not received the contribution. The ruling emphasises that taxpayers must establish the genuineness of donations claimed under Section 80GGC.
The dispute concerned whether dividend received on capital reduction by a foreign subsidiary could trigger restrictions under Section 115BBDA. ITAT held that the statutory conditions of Section 115BBDA were not satisfied, and therefore the assessment order could not be treated as erroneous or prejudicial to revenue.
The Mumbai ITAT held that Section 263 cannot be invoked merely because the Assessing Officer accepted income without making an addition after conducting enquiries. The ruling clarifies that revisionary powers require a lack of enquiry, not just a difference of opinion over the adequacy of verification.
The ITAT upheld depreciation on goodwill arising from a slump sale acquisition after finding that the business was acquired through a valid Business Transfer Agreement. The ruling confirms that goodwill valuation in a slump sale can support a depreciation claim when properly examined during assessment.
