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 Pune ITAT quashed a Section 263 revision, holding that interest earned by a credit society from deposits in co-operative banks qualifies for the Section 80P deduction as part of business income. The ruling affirms that the AO’s acceptance of the claim, being a plausible view based on precedents, cannot be set aside merely because the PCIT holds a different opinion.
Ahmedabad ITAT quashes reassessments based on ACB report, ruling the AO lacked independent “reason to believe” and only used borrowed satisfaction. A void assessment cannot be revised under Section 263.
ITAT Lucknow set aside a PCIT’s revisional order under Section 263, ruling it was void due to a violation of natural justice. The PCIT used external adverse material (alleging shell company purchases) against the assessee without providing a chance for rebuttal or considering evidence already filed, making the order invalid.
The ITAT ruled that the PCIT wrongly invoked Section 263 by relying on unverified external information (e.g., SEBI data and license suspension claims) to label purchases as bogus, without providing this information to the assessee for rebuttal. The tribunal deleted the revisionary order, confirming that the PCIT acted illegally by presuming facts and ignoring the documentary proof of purchase genuineness.
The Ahmedabad ITAT has struck down reassessment orders against Arpanbhai Virambhai Desai, holding that the AO’s reliance solely on an ACB disproportionate assets report without independent application of mind or specifying escaped income is “borrowed satisfaction,” invalidating the Section 147 jurisdiction.
ITAT Mumbai ruled that the PCIT rightly invoked revisional powers under Section 263 as the assessment order showed lack of proper inquiry, upholding the revision.
The ITAT Agra set aside the addition of ₹34.45 crore under Section 41(1) against Ginni Filaments, ruling that the evidence (creditor confirmations, invoices, and payment proof) must first be verified by the AO.
ITAT Kolkata set aside the revisionary order, finding the PCITs basis—that no supporting documents for the share LTCG were on record—was factually incorrect. The Tribunal ruled that the AO had taken a plausible view after due inquiry, and the PCIT cannot use Section 263 to substitute his own view for the AOs.
The ITAT dismissed an assessee’s quantum appeal, confirming that a ₹10.42 Cr write-off for decommissioned windmills was a capital loss, not a revenue deduction. Since the trust offered this as business income, the ITAT held the only permissible treatment was adjustment in the block of assets.
The ITAT set aside the PCIT’s revision order, confirming that the sale of an entire residential building floor-by-floor to different buyers still constitutes the sale of one single house property for Section 54 claim purposes. Since the AO had already examined the capital gains claim in detail, the assessment was neither erroneous nor prejudicial to the Revenue, invalidating the Section 263 proceedings.
