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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


Plausible View Adopted by AO Cannot Be Revised – Pune ITAT on 263 Jurisdiction

September 25, 2025 477 Views 0 comment Print

The ITAT Pune partly quashed a PCIT’s revision order against Sharada Erectors Pvt. Ltd. It ruled that the AO’s plausible view on most issues, supported by enquiry, cannot be set aside.

PCIT Cannot invoke Section 263 Where AO Conducted Full Loan Verification: ITAT Nagpur

September 24, 2025 315 Views 0 comment Print

The ITAT Nagpur has set aside a revision order by the PCIT against Nirmalkumar Agrawal (HUF). The tribunal ruled that the PCIT could not invoke Section 263 to revise an assessment where the AO had already conducted a thorough enquiry and formed a plausible view, even if a different view was possible.

ITAT Nagpur Quashes PCIT’s 263 Revision: Protective Addition Cannot Be Substituted

September 24, 2025 327 Views 0 comment Print

PCIT’s revision order on Gajanand Financial Consultancy’s protective addition was quashed by ITAT Nagpur. The Tribunal ruled the AO made a detailed enquiry, and protective additions can’t be revised when substantive ones exist.

Difference of opinion cannot justify Section 263 revision if AO taken Plausible View

September 24, 2025 606 Views 0 comment Print

Relying on Malabar Industrial, Max India, and Gabriel India precedents, ITAT ruled that when two views are possible, PCIT cannot assume jurisdiction. Original assessment for AY 2020-21 was restored.

ITAT Delhi Quashes ₹986 Cr Royalty Addition on International Shipping Income

September 24, 2025 399 Views 0 comment Print

The ITAT Delhi has cancelled a Rs.986 crore tax on Tata NYK Shipping, reiterating that international shipping income is exempt under Article 8 of the DTAA, not taxable as royalty.

Foreign Exchange Loss on Import Creditors Allowed Despite No Business: ITAT Delhi

September 23, 2025 408 Views 0 comment Print

The ITAT Delhi allowed a Rs.1.19 crore foreign exchange loss for Donyi Polo Timbers on import creditors, affirming a consistent accounting method despite a lack of business operations.

Section 263 Cannot Be Invoked Without Specific Error: ITAT Ahmedabad

September 23, 2025 483 Views 0 comment Print

The ITAT Ahmedabad quashed a PCIT order, ruling that revisional power cannot be invoked for mere verification, and a specific error must be proven to show prejudice to revenue.

Mere inadequacy of enquiry by AO cannot justify invoking Section 263

September 23, 2025 684 Views 0 comment Print

The ITAT in Mumbai has quashed a revisionary order under Section 263 of the Income Tax Act against law firm AZB & Partners. The tribunal ruled that the PCIT’s order was not justified, as the Assessing Officer had already conducted a proper enquiry and applied his mind to the issue, making it a “change of opinion,” not a “lack of enquiry.”

Time-Barred Section 148 Notice Nullifies 263 Revision: ITAT Mumbai Quashes PCIT’s Order

September 23, 2025 597 Views 0 comment Print

The ITAT ruled that a PCIT cannot use Section 263 to revise an assessment order that is “non-est” in law due to a procedural defect.

Unregistered Sale Agreement with Spouse Not Enough for 54F Claim: ITAT Hyderabad

September 20, 2025 804 Views 0 comment Print

ITAT Hyderabad upheld a revision order denying capital gains exemption, citing an unregistered sale agreement between a husband and wife as insufficient proof.

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