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...
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.
ITAT Jaipur held that addition towards unaccounted commission based on seized digital sheet without corroborative evidence is not sustainable. Accordingly, addition is deleted and said ground raised by assessee is allowed.
The Tribunal ruled that once an assessment under Section 153A is approved under Section 153D, it cannot be revised under Section 263. This reinforces limits on PCIT’s revisional powers.
The Tribunal held that investment in agricultural land in a spouse’s name qualifies for deduction under Section 54B, following Rajasthan High Court precedent.
The Supreme Court held that revision under Section 263 requires both error and prejudice to revenue. In this case, depreciation claimed by a loss-making entity was tax-neutral, so revision was invalid.
ITAT Delhi dismissed the appeal challenging PCIT’s exercise of jurisdiction under Section 263, holding that the Commissioner can revise orders even when the matter is pending before CIT(A). Key takeaway: jurisdiction under Sec. 263 extends to unresolved appeals.
ITAT Mumbai held that revisionary proceeding under section 263 of the Income Tax Act is liable to be quashed since AO took one of the possible views while allowing claim of deduction under section 54F. Accordingly, order is quashed and appeal is allowed.
ITAT Mumbai held that the Assessing Officer made detailed enquiries before allowing ESOP expenditure, invalidating the PCIT’s revision under section 263.
ITAT quashed PCIT’s Section 263 order, holding AO’s treatment of survey income as business income valid and not erroneous or prejudicial to revenue.
