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...
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.
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.
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.
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.
Read the analysis of the Tata Aig vs CIT case where ITAT Mumbai discusses revisionary powers under Section 263 and assessment errors.
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.
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.
SAP Medicals Pvt. Ltd. vs. ITO: Appeal against ITAT’s 263 ruling. Explore demonetization cash deposit issue, legal analysis, and dismissal grounds.
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.
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.