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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


Debatable Issues No Basis for Penalty Under Section 271(1)(c): ITAT Mumbai

November 8, 2025 813 Views 0 comment Print

The ITAT Mumbai dismissed the Revenue’s appeal, holding that penalty cannot be imposed where the assessee’s claim is based on a genuine interpretation of Section 44 and Rule 5 and involves a debatable issue.

PCIT Cannot Recast Business Disallowance as Unexplained Expenditure Under Section 69C

November 8, 2025 435 Views 0 comment Print

The ITAT held that the PCIT incorrectly invoked Section 263 to substitute the AO’s plausible view, ruling that a business disallowance under Section 37(1) does not automatically become deemed income under Section 69C.

ITAT Guwahati Deletes ₹1.75 Cr Cash Deposit Addition & Quashes 263 Revision

November 7, 2025 951 Views 0 comment Print

The Tribunal held that ₹1.75 crore in cash deposits were explained as redeposits from earlier withdrawals, deleting additions made under Section 69A since no evidence showed alternate use of the cash.

PCIT rightly invoked revision u/s. 263 as trade scheme payment not verified accurately

November 6, 2025 333 Views 0 comment Print

ITAT Delhi held that trade scheme payment to sales promoters whether pure reimbursement or not needs proper verification and since AO granted relief without proper verification and application of mind, PCIT rightly invoked revisionary proceedings u/s. 263.

Entire ALV Cannot Be Assessed on Partially Let Out Property: ITAT Delhi

November 6, 2025 486 Views 0 comment Print

ITAT Delhi directed the AO to compute Annual Letting Value (ALV) only for the portion of the house property actually rented out (third/fourth floors). Taxing the entire property based on assumptions, ignoring the owner’s self-occupation, was held to be unjustified.

PCIT Revision Upheld: AO Failed to Verify Low Profit Margin & Audit Need (Sec 263)

November 6, 2025 540 Views 0 comment Print

ITAT sustained PCIT’s revisional order under Section 263, ruling that AO’s mechanical acceptance of a low profit margin return without proper inquiry was both erroneous and prejudicial to Revenue’s interest. AO failed to examine applicability of mandatory audit under Section 44AB and correctness of declared profit ratio in liquor trade.

No Error, No Prejudice – AO’s ICDS Verification Upheld- ITAT Quashes 263 Action

November 6, 2025 327 Views 0 comment Print

The Kolkata ITAT quashed the Section 263 revision, confirming that the Assessing Officer (AO) had specifically examined and accepted the ICDS adjustments during scrutiny. The tribunal held that when the AO conducts due inquiry and takes a plausible view, the assessment is neither erroneous nor prejudicial to the Revenue’s interest.

AO’s acceptance of excess stock as business income upheld- 115BBE not attracted

November 6, 2025 417 Views 0 comment Print

The Tribunal held that the Assessing Officer rightly accepted excess stock and cash disclosed during survey as business income after enquiry. Section 115BBE was not applicable, and PCIT’s revision under Section 263 was invalid.

Mechanical Acceptance of Return: ITAT Upholds Section Revision in Liquor Trader’s Case

November 4, 2025 480 Views 0 comment Print

Tribunal observed that AO accepted returned income without any independent examination or inquiry. As major issues like estimation of profit in liquor trade and tax audit requirements were ignored, assessment was held erroneous. Pr. CIT’s revision under Section 263 was sustained.

ITAT Upholds Retailer’s Explanation for Cash Deposits – Addition Cut from ₹1.50 Cr to ₹5 Lakh

November 4, 2025 429 Views 0 comment Print

Tribunal ruled that high-rate tax under Section 115BBE cannot be applied to assessment year 2017-18 cash deposit, as section applies only to transactions on or after April 1, 2017. Decision directs AO to compute consequential tax liability under normal provisions.

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