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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 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 429 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Income Tax : The Tribunal accepted that the deposits represented funds withdrawn earlier for house construction.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


Section 264 empowers Tax Authorities to Correct Mistakes by Officials or Taxpayers

February 20, 2025 2751 Views 0 comment Print

Delhi High Court overturns order in Interglobe Enterprises vs. PCIT case, ruling that ₹1.51 crore interest income cannot be taxed twice. Case remanded for reassessment.

Section 264: CIT must Correct Errors by Authorities or Assessees to Provide Relief

February 20, 2025 1731 Views 0 comment Print

Delhi HC clarifies the wide scope of Section 264 of the Income Tax Act, emphasizing that the Commissioner must address errors leading to over-assessment, even if raised for the first time in a revision application.

Section 264 Revision Accepted: Suo Moto Disallowance Rectified

February 12, 2025 957 Views 0 comment Print

Delhi High Court held that suo moto disallowance with bona fide yet mistaken belief that amount is liable to be offered for taxation, such mistake can be rectified via revision application under section 264 of the Income Tax Act.

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