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 held that once the underlying Section 263 revision was set aside, the consequential assessment lost legal validity. The key takeaway: without a valid foundation, no further appellate proceedings can survive.
This case examines whether the PCIT could revise an assessment under section 263 when the AO allowed interest income deduction under section 80P. The ITAT ruled that the AO’s order was a plausible view, and both conditions for invoking section 263 were not met.
The ITAT held that an assessee’s procedural lapses cannot override statutory entitlement to deductions under section 10A. The AO must verify substantive conditions, including STPI registration and export realization, before rejecting a claim.
Tribunal held that AO had conducted detailed inquiries on a partner’s debit balance and correctly accepted it as capital withdrawal, not a loan. PCIT’s revision under Section 263 was based on assumptions and a change of opinion, not any factual error. The order was quashed.
Court upheld Tribunal’s finding that Assessing Officer examined cash deposits and adopted a permissible view by treating them as sales. Since the issue had been enquired into and two views were possible, revision under Section 263 could not be justified.
The court upheld the Tribunal’s view that the AO had examined salary and business promotion expenses, making Section 263 revision invalid. It held that when two views are possible, revisional interference is unwarranted.
The AO’s assessment included detailed examination of depreciation, warranty provisions, and Section 80G deductions for CSR donations. ITAT Ahmedabad found that the AO’s conclusions were plausible and in line with judicial precedents. The revisionary order under Section 263 was quashed, affirming that the AO’s order was not erroneous or prejudicial to Revenue.
The Tribunal held that the revisionary order was invalid because the authority failed to demonstrate how the assessment was erroneous or prejudicial to revenue. The AO’s enquiries and acceptance of a plausible view were upheld.
ITAT Delhi held that PCIT’s revision under section 263 on alleged bogus sales was invalid since the same transactions were already under appeal before CIT(A). Substituting the AO’s judgment without showing assessment was erroneous and prejudicial was impermissible.
The case examined whether the tax officer was justified in rejecting the assessee’s DCF-based share valuation under Section 56(2)(viib). The Tribunal held that once DCF is chosen, the AO cannot switch to NAV merely because subsequent financials differ from projections
