Home Highlights July 2020 Year 2020 This

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1. Revision u/s 263 - Ld. Pr. CIT exercising jurisdiction under section 263 of the Act, directed the AO to make fresh assessment on the issues which were not the subject...

2. Revision u/s 263 or appeal-able order before CIT(A) u/s 246A - Subject matter of revision was limited - Doctrine of merger - CIT(A) and ITAT rejected the appeal of...

3. Revision u/s 263 - period of limitation for passing order - Only in a case where the issues before the Commissioner at the time of exercising powers u/s 263 relate to...

4. Revision u/s 263 by CIT - the assessee had duly explained as to why certain receipts though subjected to TDS, would not be liable to be offered to tax such as...

5. Revision u/s 263 by CIT - As both the issues in question on the basis of which the Pr.CIT had assumed jurisdiction u/s 263 of the Act had been considered and decided in...

6. Revision u/s 263 by CIT - Jurisdiction exercised by ld PCIT under section 263 of the Act is not in accordance with law. PCIT has selected the item (share capital and...

7. Revision u/s 263 - the issue was duly considered by Ld. AO after considering assessee’s detailed submissions. The view could not be said to be unsustainable view and it...

8. Revision u/s 263 - in original assessment AO estimated net profit @ 7% which was reduced by CIT(A) @ 5% - It is not in dispute that issue on which the remand order was...

9. Revision u/s 263 - Issue considered and decided in appeal by appellate authorities, such matters cannot be subject to revision u/s 263. Rationale behind exclusion of...

10. Revision u/s 263 - Jurisdiction of CIT when the matter is pending before the CIT(A) - It is not a separate issue, which has to be taken care in revisionary jurisdiction....

11. Revision u/s 263 by CIT - Whether assessment order has been made subject matter of Vivad Se Vishwas Scheme, the ld. Pr.CIT cannot exercise jurisdiction u/s 263 ? - since...

12. Doctrine of merger - Validity of Revision u/s 263 when existing pending appeal against order passed u/s 153C r.w.s. 144 - when larger issue was pending before CIT(A),...

13. Revision u/s 263 by CIT - requirement of issuing show-cause notice - there is nothing in the Section 263 to raise the said notice to the status of a mandatory show-cause...

14. Revision u/s 263 - Doctrine of merger - the subject-matter in question “Disallowance under section 14A r.w.r.8D” ‘ has been considered and decided by the Commissioner of...

15. Revision u/s 263 - Scope of audit objection - The entire exercise seems to have been done because of audit objection only. Since, the Assessing Officer had duly enquired...