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 Tribunal ruled that Section 263 jurisdiction is barred under Explanation 1(c) if the matter is under appeal before CIT(A). AO’s assessment, including enquiry into statements and ledgers, was found proper. PCIT’s revision attempting to tax full Rs.1.59 Cr as bogus purchase was quashed.
Because differing judicial views existed on taxation of co-operative society interest income, the AO’s accepted position could not be termed erroneous. The Tribunal ruled that debatable issues cannot trigger section 263 revision.
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.
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.
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.
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.
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.
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.
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).
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.
