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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 765 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 2397 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 708 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 828 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 972 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 10689 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 8235 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 7326 Views 0 comment Print


Latest Judiciary


Assessment Order Passed on Deceased Person Is Nullity in Law: ITAT Ahmedabad

Income Tax : ITAT held an assessment passed after the taxpayer's death was invalid in law, quashed the order, and treated all remaining issues ...

July 4, 2026 162 Views 0 comment Print

ITAT Deletes Additions as AO Made No Independent Inquiry Beyond ACB Information

Income Tax : ITAT deleted additions after finding the AO relied only on ACB information without independent inquiry or supporting evidence. ITA...

July 2, 2026 138 Views 0 comment Print

Loan to Non-Shareholder Company Not Taxable as Deemed Dividend

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...

July 1, 2026 456 Views 0 comment Print

Bombay HC Rejects Section 263 Revision as AO Conducted Necessary Inquiry

Income Tax : The Court held that Section 263 could not be invoked where the AO had made inquiries and accepted the assessee's explanation....

June 30, 2026 171 Views 0 comment Print

Section 263 Revision Invalid if CIT Failed to Show Assessment Was Erroneous

Income Tax : The Court held that Section 263 could not be invoked where the AO had raised queries, examined replies and completed the assessmen...

June 30, 2026 135 Views 0 comment Print


Omission to Disallow Interest on Unexplained Loans is Error – 263 Jurisdiction Valid

September 27, 2025 453 Views 0 comment Print

ITAT Ahmedabad upheld PCIT’s revisionary order, ruling that AO’s failure to disallow interest (Rs.44.51 lakh) on unsecured loans (Rs.92 lakh) already deemed unexplained was an erroneous and prejudicial’ omission, not merely a difference of opinion.

ITAT Quashes 263 Revision on Political Donation – AO’s Enquiry Found Sufficient

September 27, 2025 2163 Views 0 comment Print

ITAT Ahmedabad quashed the PCIT’s Section 263 revision setting aside an assessment, holding AO’s enquiry into an Section 80GGC political donation was plausible and adequate.

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

September 25, 2025 534 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 351 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 411 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 672 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 432 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 459 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 516 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 753 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.”

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