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Section 264

Latest Articles


Power of Best Judgement Assessment of Assessing Officer under Income Tax Laws

Income Tax : An overview of Section 144 of the Indian Income Tax Act, which allows an Assessing Officer to make a best judgment assessment in c...

September 20, 2025 780 Views 0 comment Print

Revisionary Powers under Sections 263 & 264 of Income Tax Act, 1961

Income Tax : An analysis of Sections 263 and 264 of the Income-tax Act, 1961. It details the conditions, scope, and judicial precedents for the...

September 16, 2025 432 Views 0 comment Print


Latest Judiciary


Patna ITAT quashes Section 270A Penalty for Lack of Timely Immunity Order

Income Tax : Relying on the Schneider Electric judgment of the Delhi High Court, the ITAT held that absence of a separate immunity order within...

November 1, 2025 354 Views 0 comment Print

Reopening Based on IDS Disclosure Invalid: Bombay HC Slams Revenue for “Abuse of Power”

Corporate Law : Bombay High Court quashed reassessment proceedings initiated using data from a valid IDS declaration, holding that once accepted u...

October 27, 2025 348 Views 0 comment Print

Karnataka HC Allows Condonation for 67-Year-Old Who Mistakenly Filed Form 68 Manually Instead of Online

Income Tax : The Karnataka High Court set aside the PCIT's rejection of a condonation delay application for late online Form 68 filing. The cou...

October 26, 2025 153 Views 0 comment Print

ITAT Delhi Deletes Capitation Fee Additions Against Educational Trust

Income Tax : The Income Tax Appellate Tribunal (ITAT), Delhi, ruled against the revenue's additions of unaccounted capitation fees and cash loa...

October 3, 2025 216 Views 0 comment Print

Once Appeal withdrawn & Revision allowed u/s 264, CIT(A) has no jurisdiction

Income Tax : ITAT Delhi ruled a CIT(A) order invalid, stating it had no jurisdiction once a superior authority (PCIT) had already allowed a rev...

August 23, 2025 309 Views 0 comment Print


Latest Posts in Section 264

Patna ITAT quashes Section 270A Penalty for Lack of Timely Immunity Order

November 1, 2025 354 Views 0 comment Print

Relying on the Schneider Electric judgment of the Delhi High Court, the ITAT held that absence of a separate immunity order within one month does not justify penalty imposition.

Reopening Based on IDS Disclosure Invalid: Bombay HC Slams Revenue for “Abuse of Power”

October 27, 2025 348 Views 0 comment Print

Bombay High Court quashed reassessment proceedings initiated using data from a valid IDS declaration, holding that once accepted under the Income Disclosure Scheme, the Revenue cannot revisit or reassess the same income.

Karnataka HC Allows Condonation for 67-Year-Old Who Mistakenly Filed Form 68 Manually Instead of Online

October 26, 2025 153 Views 0 comment Print

The Karnataka High Court set aside the PCIT’s rejection of a condonation delay application for late online Form 68 filing. The court adopted a justice-oriented view, directing a fresh, liberal reconsideration, as the taxpayer’s manual compliance was timely and the error was bona fide.

ITAT Delhi Deletes Capitation Fee Additions Against Educational Trust

October 3, 2025 216 Views 0 comment Print

The Income Tax Appellate Tribunal (ITAT), Delhi, ruled against the revenue’s additions of unaccounted capitation fees and cash loan interest under Sections 69A and 69C against the Saraswati Ammal Educational & Charitable Trust.

Power of Best Judgement Assessment of Assessing Officer under Income Tax Laws

September 20, 2025 780 Views 0 comment Print

An overview of Section 144 of the Indian Income Tax Act, which allows an Assessing Officer to make a best judgment assessment in cases of non-compliance.

Revisionary Powers under Sections 263 & 264 of Income Tax Act, 1961

September 16, 2025 432 Views 0 comment Print

An analysis of Sections 263 and 264 of the Income-tax Act, 1961. It details the conditions, scope, and judicial precedents for these revisional powers.

Once Appeal withdrawn & Revision allowed u/s 264, CIT(A) has no jurisdiction

August 23, 2025 309 Views 0 comment Print

ITAT Delhi ruled a CIT(A) order invalid, stating it had no jurisdiction once a superior authority (PCIT) had already allowed a revision under Section 264.

No Second Bite at the Cherry- ‘Set Aside’ u/s 264 means Assessment Quashed

August 23, 2025 648 Views 0 comment Print

ITAT Bangalore ruled that an AO cannot re-initiate assessment after a PCIT ‘sets aside’ an order without providing fresh directions, quashing a cash deposit addition.

Section 264: Revisional Authority Can Review Existing Orders, Cannot Direct AO

July 24, 2025 297 Views 0 comment Print

Kerala High Court rules Section 264 revisional authority can only review existing orders, not issue directions to Assessing Authority; clarifies limitation period.

Best judgement assessment without hearing opportunity is not sustainable: Matter remanded

June 16, 2025 255 Views 0 comment Print

Gujarat High Court held that Revisional authority ought to have taken into consideration that AO has to pass best judgement assessment order without granting an opportunity of being heard. Thus, matter remanded back to AO for de novo consideration.

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