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 Tribunal ruled that both conditions for Section 263 revision must exist simultaneously. Since no exempt income was earned, the assessment order was neither erroneous nor prejudicial.
The Tribunal ruled that simultaneous proceedings arising from reassessment and revision for the same year could lead to multiplicity of proceedings and inconsistent findings. It restored the entire matter to the Assessing Officer for consolidated de-novo adjudication.
The ITAT relied on surrounding circumstances, documentary evidence, and the principle of human probabilities to conclude that cash consideration was paid in a land transaction. The Tribunal confirmed the addition of unaccounted sale consideration as short-term capital gains.
The Court directed the PCCIT to appoint a senior officer to re-examine a refund claim where both parties lacked decades-old records. A reasoned decision must be taken to ensure any legitimate refund is not denied.
The Tribunal upheld addition under Section 69 as the assessee failed to establish that the LIC investment belonged to the HUF. Mere assertion of agricultural income without documentary evidence was held insufficient.
ITAT Delhi held that interest awarded under Section 28 is an accretion to compensation and cannot be taxed as income from other sources. The appeal was allowed following Supreme Court precedent.
ITAT Delhi held that initiation of re-assessment proceedings under section 148 of the Income Tax Act is liable to be quashed as without jurisdiction since revisionary proceedings under section 263 on the same issue was already dropped.
The ITAT Kolkata held that revision under Section 263 was invalid where the Assessing Officer had already examined service tax liability and depreciation claims during assessment. The order was not erroneous or prejudicial to Revenue.
The Tribunal held that where the AO had examined and accepted exemption on interest under Section 28 of the Land Acquisition Act, revision under Section 263 was not justified.
ITAT Panaji held that disallowance of audit fees is not justifiable since commencement of business operation is recognised under the Companies Act and expenditure was incurred wholly and exclusively for business. Accordingly, appeal allowed to that extent.
