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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


HC Quashes Section 263 Order and Imposes Rs 10,000 Cost on PCIT

August 18, 2023 10980 Views 0 comment Print

Allahabad High Court quashes Section 263 order and imposes cost of Rs 10,000 on PCIT for lack of proper opportunity. Analysis of the judgment in M.L. Chains Vs PCIT case.

Invocation of section 263 unjustified as order not prejudicial to revenue

August 17, 2023 966 Views 0 comment Print

ITAT Mumbai held that since the impugned MTM loss was duly reversed in the subsequent year and offered to tax, revisionary proceedings invoked under section 263 of the Income Tax Act cannot be sustained as there is no prejudice to the revenue.

Revisionary Powers under Section 263: Error Must Be Factual or Legal

August 15, 2023 2331 Views 0 comment Print

Read the analysis of the Tata Aig vs CIT case where ITAT Mumbai discusses revisionary powers under Section 263 and assessment errors.

Section 80IC deduction cannot be disallowed arbitrarily in subsequent years

August 14, 2023 1794 Views 0 comment Print

Analysis of C & E Limited Vs PCIT case on disallowance of deduction u/s 80IC in subsequent years. Examining the legality & Calcutta High Court’s decision.

Matter already considered and decided by CIT(A) cannot be re-considered in revision proceeding

August 11, 2023 600 Views 0 comment Print

ITAT Delhi held that once a matter has been considered and decided by the ld.CIT(A), the very same issue cannot be the subject matter of consideration at all by PCIT in the revision proceedings either on substantive basis or on protective basis. Accordingly, revision order quashed.

ITAT Upholds invocation of Section 263 for demonetized Cash Deposit & Acceptance

August 6, 2023 1710 Views 0 comment Print

SAP Medicals Pvt. Ltd. vs. ITO: Appeal against ITAT’s 263 ruling. Explore demonetization cash deposit issue, legal analysis, and dismissal grounds.

Section 263 Not Invocable as Plausible View on Service Tax Return & ITR Difference taken by AO

August 6, 2023 600 Views 0 comment Print

ITAT Mumbai held that invocation of section 263 alleging difference in the receipt as per service tax return and ITR filed unsustainable as AO after making an enquiry on this issue has taken one of the plausible view and has not made addition on the difference amount.

PCIT cannot exercise revisionary jurisdiction under section 263 on material not confronted to assessee 

August 5, 2023 1164 Views 0 comment Print

Analyzing the High Court case, ACIT Vs Sun and Sun Inframetric Pvt. Ltd., focusing on the PCIT’s ability to exercise revisionary jurisdiction under Section 263.

Acceptance of Project Completion Method followed by Assessee consistently by AO not erroneous

August 5, 2023 9945 Views 0 comment Print

An overview of case, Parth Developers vs PCIT, where ITAT rules that PCIT can’t invoke Section 263 for a project completion method consistently used by AO.

PCIT cannot Initiate Revision Proceedings after disposal of appeal by CIT(A)

August 4, 2023 948 Views 0 comment Print

CIT(A) resolved the appeal, considering the TDS credit issue, on 08/05/2019. Therefore, PCIT can’t invoke s.263 revision proceedings for the same issue, per Explanation-1(c) to section 263(1) of the Act.

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