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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 765 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 2394 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 708 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 828 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 972 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 10689 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 8235 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 7326 Views 0 comment Print


Latest Judiciary


Assessment Order Passed on Deceased Person Is Nullity in Law: ITAT Ahmedabad

Income Tax : ITAT held an assessment passed after the taxpayer's death was invalid in law, quashed the order, and treated all remaining issues ...

July 4, 2026 162 Views 0 comment Print

ITAT Deletes Additions as AO Made No Independent Inquiry Beyond ACB Information

Income Tax : ITAT deleted additions after finding the AO relied only on ACB information without independent inquiry or supporting evidence. ITA...

July 2, 2026 138 Views 0 comment Print

Loan to Non-Shareholder Company Not Taxable as Deemed Dividend

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...

July 1, 2026 450 Views 0 comment Print

Bombay HC Rejects Section 263 Revision as AO Conducted Necessary Inquiry

Income Tax : The Court held that Section 263 could not be invoked where the AO had made inquiries and accepted the assessee's explanation....

June 30, 2026 171 Views 0 comment Print

Section 263 Revision Invalid if CIT Failed to Show Assessment Was Erroneous

Income Tax : The Court held that Section 263 could not be invoked where the AO had raised queries, examined replies and completed the assessmen...

June 30, 2026 135 Views 0 comment Print


Passing of revisionary order u/s 263 without issuance of notice on subject matter is unjustified

August 20, 2023 786 Views 0 comment Print

ITAT Surat restored the matter back to the file of Pr. CIT as revisionary order under section 263 of the Income Tax Act cannot be passed without issuance of show cause notice on the subject matter. Such revisionary order is against the principal of natural justice.

CIT rightly Invoked Section 263 for Oversight in examining Composite Property Agreement

August 18, 2023 780 Views 0 comment Print

ITAT Kolkata held that AO failed to examine the agreement as composite agreement and hence non-examination of AO with that angle has caused prejudice to the interest of Revenue and hence CIT rightly set aside the assessment order by exercising powers under section 263 of the Income Tax Act.

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

August 18, 2023 11043 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 1023 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 2358 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 1881 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 639 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 1752 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 645 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 1197 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.

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