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Section 264

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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 2346 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 3471 Views 0 comment Print


Latest Judiciary


Retired Bank Employee Gets Relief as Leave Encashment Was Within Revised ₹25 Lakh Limit

Income Tax : The ITAT held that leave encashment of ₹6.97 lakh was fully exempt as it fell within the revised ₹25 lakh ceiling under Notifi...

May 29, 2026 195 Views 0 comment Print

Leave Encashment Addition Deleted as CBDT Increased Exemption Ceiling to ₹25 Lakh

Income Tax : The ITAT allowed exemption of the entire leave encashment amount after noting that the revised ₹25 lakh ceiling exceeded the amo...

May 29, 2026 78 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 237 Views 0 comment Print

Bombay HC Quashes Reassessment as Limitation Expired Before Assessment Order Was Passed

Income Tax : The Bombay High Court held that reassessment proceedings became time-barred because no reassessment order was passed within the li...

May 12, 2026 267 Views 0 comment Print

ITAT Kolkata Allows Foreign Tax Credit Despite Late Filing of Form 67

Income Tax : The ITAT Kolkata held that delayed filing of Form No. 67 is only a procedural defect and cannot deprive an assessee of Foreign Tax...

May 12, 2026 255 Views 0 comment Print


Section 264 Revision Cannot Be Denied on Technicalities for Elderly Alzheimer’s Patient

December 1, 2025 855 Views 0 comment Print

The High Court held that the Commissioner did not properly apply the wide discretionary powers under section 264. The matter was remanded for fresh consideration in light of the petitioner’s circumstances and submitted records.

Scrutiny assessment of ‘receipts of trust’ does include appropriation of the same

November 26, 2025 273 Views 0 comment Print

The Kerala High Court held that scrutiny of exempted trust returns was correctly conducted as complete scrutiny, allowing assessment of appropriation of receipts under Section 12A.

CIT(A)’s Jewellery Reconciliation Upheld: Unexplained Investment u/s 69 Deleted

November 23, 2025 1341 Views 0 comment Print

ITAT held that most jewellery seized during a search could be accounted for from declared drawings and past income, reducing addition to ₹72.45 lakh. Ruling emphasizes that unexplained investment must be proven in relevant assessment year.

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

November 1, 2025 828 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 645 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 636 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 429 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 2346 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 3471 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 690 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.

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