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 ITAT held that CSR expenditure disallowed as business expenditure under Section 37(1) can still qualify for deduction under Section 80G if statutory conditions are satisfied. Revision under Section 263 was accordingly quashed.
Mumbai ITAT held that no further profits can be attributed to a DAPE once the Indian agent is remunerated at arm’s length for all FAR functions. The Tribunal rejected the Revenue’s “double profit attribution” theory and deleted the enhanced PE addition.
The ITAT ruled that penalty proceedings under Section 271D are invalid if the Assessing Officer fails to record satisfaction in assessment or related proceedings. Since no assessment proceedings existed in the case, the penalty was held unsustainable in law.
The Tribunal held that lack of inquiry into a large receipt justified revision under Section 263. It found the assessment erroneous and prejudicial to revenue. The ruling reinforces duty of proper verification.
The Tribunal held that revisionary powers cannot be used to substitute the AO’s view with that of the Pr. CIT. It emphasized that such substitution is beyond Section 263. The decision protects independent assessment decisions.
The case examined whether property registered in trustees’ names violated Section 13(1)(c). The Tribunal held no violation as no benefit accrued to trustees, allowing exemption under Section 11.
The issue was whether contractor deposits could be treated as unexplained credits. The Tribunal held they were genuine trade liabilities, not taxable under Section 68.
The case examined whether revision under Section 263 was validly invoked. The High Court held that reliance on the Assessing Officer’s reference without independent application of mind invalidated the revision.
The case examined whether scrutiny selection without meeting CBDT conditions was valid. The ITAT held that failure to satisfy mandatory criteria invalidated the notice and entire assessment.
The tribunal examined whether depreciation can be claimed on concession rights under a BOT/DBFOT project. It held that the right to receive annuity/toll is an intangible asset eligible for depreciation under tax law.
