Follow Us:

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 2061 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 2748 Views 0 comment Print


Latest Judiciary


Reassessment Notice Quashed Due to Extinguishment of Tax Liabilities Under Approved Resolution Plan

Income Tax : The High Court held that once a resolution plan under IBC extinguishes prior tax liabilities, reassessment cannot be initiated. Th...

April 1, 2026 513 Views 0 comment Print

Foreign Tax Credit (FTC) Allowed Despite Delay in Filing Form No. 67

Income Tax : The Tribunal held that delay in filing Form 67 is a procedural lapse. It restored the matter to the AO to verify and allow Foreign...

March 19, 2026 642 Views 0 comment Print

Penalty U/s 271DA & 271E Invalid When Original Assessment Set Aside – ITAT Deletes Penalties

Income Tax : The tribunal examined whether penalties could continue when the fresh assessment order did not record satisfaction for initiating ...

March 14, 2026 426 Views 0 comment Print

ITAT Bangalore Deletes Sec 69A Addition on Demonetisation Cash Deposits Explained by Earlier Withdrawals

Income Tax : The Tribunal accepted that the deposits represented funds withdrawn earlier for house construction. Since the explanation was supp...

March 5, 2026 351 Views 0 comment Print

No Section 263 Revision When Two Views Possible on Section 28 Interest on Enhanced Compensation

Income Tax : The Tribunal held that where the AO had examined and accepted exemption on interest under Section 28 of the Land Acquisition Act, ...

February 25, 2026 321 Views 0 comment Print


IDS Liability: Self-Assessment Tax Must Be Adjusted; Form-4 Denial Arbitrary

January 15, 2026 318 Views 0 comment Print

The Court held that self-assessment tax paid due to failure of an initial IDS declaration must be treated as payment under the revived Scheme, preventing double taxation of the same income.

PCIT Must Follow ITAT Special Bench Despite Pending Appeal: Bombay HC

January 14, 2026 771 Views 0 comment Print

The High Court ruled that tax authorities cannot ignore a binding ITAT Special Bench decision under Section 264 merely because the department has appealed it. Judicial discipline requires adherence unless the ruling is stayed or overturned.

Reassessment After Four Years Invalid for Change of Opinion: ITAT Chennai

January 8, 2026 402 Views 0 comment Print

The issue was whether reassessment could be initiated beyond four years after a completed scrutiny assessment. The Tribunal held that reopening was barred as there was no failure to disclose material facts.

Charitable Exemption Denial Quashed Due to Correctable ITR Mistakes

January 5, 2026 798 Views 0 comment Print

The issue was whether exemption under Section 11 could be denied solely due to wrong data punching. The court ruled that inadvertent human errors cannot defeat a lawful exemption

World Cup Sponsorship Payment Split Into Ad Spend and Royalty

December 30, 2025 315 Views 0 comment Print

The Delhi High Court held that sponsorship payments included consideration for worldwide use of event trademarks. The ruling confirms that such rights constitute royalty liable to withholding tax.

Order of Competent Authority granting or refusing sanction u/s. 151 is not appealable order

December 27, 2025 417 Views 0 comment Print

Uttarakhand High Court held that order of the Competent Authority granting sanction or approval or refusing to grant sanction or approval u/s 151 of the Income Tax Act of 1961 is neither a revisable order, nor an appealable order.

Section 271D Penalty Quashed as Time-Barred in Absence of Assessment: ITAT Chennai

December 25, 2025 1251 Views 0 comment Print

The Tribunal held that penalties under Section 271D were invalid as they were imposed beyond the limitation period prescribed under Section 275(1)(c).

Post condoning delay, revisional authority wrongly dismissed petition u/s. 264 on ground of delay

December 25, 2025 291 Views 0 comment Print

Karnataka High Court held that revision petition u/s. 264 of the Income Tax Act wrongly dismissed by holing that delay in filing revision petition cannot be condoned since the revisional authority already condoned the delay.

Section 264 Relief Cannot Be Denied Merely Due to Pending SC Issue: Delhi HC

December 22, 2025 507 Views 0 comment Print

The Court held that relief cannot be denied under Section 264 merely because a similar issue was earlier pending before the Supreme Court. The revision application was allowed as the issue was already covered by binding High Court rulings.

Section 144C Can’t Extend Limitation: TP Assessment Quashed as Time-Barred

December 22, 2025 420 Views 0 comment Print

The dispute centered on whether DRP directions allow completion of assessment beyond statutory time limits. The Tribunal clarified that section 144C does not create an independent limitation period. Procedural timelines cannot defeat the mandatory bar under section 153.

Search Post by Date
April 2026
M T W T F S S
 12345
6789101112
13141516171819
20212223242526
27282930