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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 135 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


Revision u/s 263 sustained as assessment completed in a routine and mechanical manner

January 20, 2024 876 Views 0 comment Print

ITAT Mumbai held revisionary order under section 263 of the Income Tax Act to be proper and just as assessment was completed in a routine and mechanical manner without due diligence and without due application of mind.

CIT(A) cannot exercise enhancement power on issue not dealt by AO

January 18, 2024 1989 Views 0 comment Print

ITAT Mumbai held that CIT(A) cannot exercise the power to enhance u/s. 251(1) where AO has not dealt with the issue and has not applied his mind on the taxability or non-taxability of a specific matter. Accordingly, exercise such power by CIT(A) will be beyond his jurisdiction.

Section 263: Revision unjustified as AO took possible view based on available records

January 18, 2024 1008 Views 0 comment Print

ITAT Mumbai held that revision under section 263 of the Income Tax Act unjustified as AO while allowing the exemption in the order passed under section 144 r.w.s.263 has taken a possible view upon verifying the details available on record.

TDS not deductible from discount paid on prepaid sim card/ recharge vouchers

January 17, 2024 1293 Views 0 comment Print

ITAT Mumbai held that the assessee is not liable to deduct tax at source from the discount paid on prepaid sim card/recharge vouchers. Thus, disallowance made u/s 40(a)(ia) of the Income Tax Act liable to be deleted.

Revisionary order unsustainable as issue of exemption u/s 11 considered during scrutiny assessment

January 16, 2024 819 Views 0 comment Print

ITAT Chennai held that the assessment order passed by the AO is neither erroneous nor prejudicial to the interest of the Revenue, because, the issue of exemption u/s.11 of the Act, has been considered by the AO while completing assessment u/s.143(3) of the Act. Thus, order passed by the CIT(Exemptions) u/s.263 of the Act unsustainable.

Conditions for invoking Section 263: AO Order must be Erroneous & Prejudicial to Revenue

January 16, 2024 993 Views 0 comment Print

Explore the Delhi High Court’s judgment on CIT – International Taxation, highlighting the invalidity of invoking S. 263 without satisfying twin conditions. Full analysis and implications.

Plea of defect in the notice not accepted as it had caused no prejudice to assessee

January 16, 2024 1713 Views 0 comment Print

Bombay High Court held that plea of defect in the notice cannot be accepted as it had caused no prejudice to the assessee and the assessee “clearly understood” what was the purport and import of notice issued under section 274 read with Section 271 of the Act.

AO Conducted Enquiry on High Premium Shares; PCIT Error in Section 263 Exercise: HC

January 16, 2024 1599 Views 0 comment Print

Delhi High Court ruling on PCIT vs Trojan Developers Pvt. Ltd. AO’s enquiry on high premium shares and HC’s critique of Section 263 exercise. Full text of judgment.

Denial of 80IA Benefit in 4th Year Unjustified: Delhi HC

January 10, 2024 942 Views 0 comment Print

Delhi High Court ruling on Income Tax: Department’s U-turn on 80IA deduction in the 4th year deemed unjustified. Case analysis of PCIT vs. BT Global Communications India Pvt. Ltd.

No Section 263 Revision for Non-Limited Scrutiny Issues in Limited scrutiny cases: ITAT

December 30, 2023 1032 Views 0 comment Print

ITAT Chennai rules no 263 revision for non-limited scrutiny issues. Upholds assessment order in Epimoney Pvt Ltd vs. ITO case for AY 2018-19.

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