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 ...
Delhi High Court held reassessment under Sections 147/148 cannot be initiated merely on an internal audit objection. Absence of new tangible material made reopening invalid.
The AO recorded reasons for escapement without receiving confirmation from the Sub-Registrar. ITAT ruled that absence of tangible evidence vitiated reassessment, making the subsequent Section 263 revision unsustainable.
The Tribunal ruled that Section 263 cannot be invoked merely because the Commissioner holds a different opinion. Once adequate inquiry is conducted and a reasonable view is taken, revision is unsustainable.
The Tribunal ruled that reopening based merely on audit objection without independent application of mind is unsustainable. An audit note cannot replace the Assessing Officers reasoned belief.
The Tribunal ruled that once the Assessing Officer scrutinized the Section 10AA claim and R&D allocation, revision cannot be invoked. Section 263 cannot be used to re-examine issues already verified during assessment.
The ITAT deleted addition under Section 69A where cash deposits were made in a joint account. Since the husband owned the deposits and was not cross-examined, taxing the wife was held unjustified.
The Tribunal ruled that accepting share capital and unsecured loans without proper verification violates Section 68 requirements. It upheld the Principal CITs revision order, stating that failure to investigate renders the order prejudicial to revenue.
ITAT ruled that mere acceptance of exemption without examining statutory amendments constitutes non-application of mind. The Principal Commissioner rightly invoked Section 263 where binding High Court rulings were ignored.
The Tribunal ruled that failure to verify discrepancies in quantitative stock details justified revisionary action. Mere calling of documents without proper examination invites Section 263 proceedings.
The PCIT questioned deduction under Section 80JJAA and CSR expenses but failed to record specific findings. The Tribunal held that absence of independent verification and reasoning renders the Section 263 order invalid.
