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 : The ITAT Amritsar held that a valuation report by itself cannot justify addition under Section 69 without evidence of extra paymen...
Income Tax : ITAT Mumbai held that amortization of BOT road project expenditure must be computed based on the actual concession period and not ...
Income Tax : The Tribunal held that the reassessment order could not be revised under Section 263 since the conditions for treating jewellery e...
Income Tax : ITAT Hyderabad held that assessment orders passed pursuant to earlier remand directions were barred by limitation under Section 15...
Income Tax : Delhi ITAT held that an Assessing Officer cannot make additions beyond the specific issues remanded by the Principal Commissioner ...
The ITAT held that the PCIT cannot invoke revisionary powers when the same issue is already pending before the appellate authority. The case involved share transaction additions treated as penny stock.
The High Court held that once a resolution plan under IBC extinguishes prior tax liabilities, reassessment cannot be initiated. The notice under Section 148 was set aside. The ruling confirms that extinguished claims cannot be revived through reassessment.
ITAT held that revision under Section 263 cannot be invoked when the Assessing Officer has already examined the issue. The ruling emphasizes that mere disagreement with enquiry results does not justify revision.
The Tribunal held that an assessment order passed in compliance with DRP directions cannot be revised under Section 263. It clarified that such orders are not erroneous as the Assessing Officer is bound by DRP’s binding instructions.
The Tribunal held that transfer pricing adjustment cannot survive without a final assessment order post-DRP directions. Repeating such addition in a Section 263 order was held invalid.
The issue involved revision of assessment where income was declared under Section 44AD. The Tribunal held that absence of books makes Section 68 inapplicable. The takeaway is that revision cannot be based on lack of records not required by law.
The issue was whether the assessment order could be revised for lack of inquiry. The Tribunal held that since the Assessing Officer had examined the issues and taken a view, revision under Section 263 was not justified.
The Tribunal examined whether foreign assignment salary credited in India is taxable. It held that salary for services rendered outside India is not taxable, even if received in India.
ITAT Chennai held once the AO has conducted inquiry, examined replies and adopted a legally sustainable view, the same cannot be treated as erroneous. Accordingly, invocation of revisionary jurisdiction under section 263 of the Income Tax Act is not sustainable in law.
The Tribunal held that revision under Section 263 is invalid without proving both error and revenue prejudice. The AO’s order was restored as valid.
