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 tribunal ruled that revisionary powers cannot be exercised without questioning the statutory approval under Section 153D. Absence of such examination renders Section 263 action invalid.
The court examined whether interest on FDRs could be taxed as other income. It held that where funds are linked to a project, the interest retains its project nexus and is not separately taxable.
The case examined whether reassessment proceedings were valid when approval was obtained from an incorrect authority. The Court held the sanction invalid as it did not comply with statutory requirements, rendering the reassessment void. The ruling highlights strict adherence to approval hierarchy in reopening cases.
ITAT Delhi held that revisionary proceedings under 263 of the Income Tax Act justifiable since related-party expenses were accepted without detailed verification. Accordingly, revision is upheld and the present appeal is dismissed.
ITAT Mumbai held that CIT(A) cannot enhance income by introducing a new issue not examined by the Assessing Officer. The ruling clarifies that such action exceeds jurisdiction under Section 251 and must be addressed through other provisions.
ITAT Bangalore quashed Section 263 revision, holding that AOs acceptance of FMV based on valuers report was a plausible view after enquiry and non-reference to DVO or non-initiation of penalty cannot render the order erroneous or prejudicial.
The Court held that electricity duty collected by a licensee is not its own liability but that of consumers. As a result, Section 43B was found inapplicable and the disallowance was rightly deleted.
The Tribunal held that the Assessing Officer went beyond revisionary directions by including additional issues. It ruled that such excess additions were invalid and liable to be deleted.
The tribunal reversed the CIT(A)’s decision for wrongly quashing assessment due to lack of notice under Section 143(2). It held that Section 263 proceedings are a continuation of original assessment.
ITAT held that reassessment initiated with approval from the wrong authority is invalid when issued beyond three years. The entire proceedings were quashed. The key takeaway is that proper sanction under Section 151 is mandatory.
