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Income Tax - Highlights / Catch Notes

Home Highlights June 2022 Year 2022 This

Revision u/s 263 by CIT - having invoking the powers u/s.263 of ...

Income Tax

June 22, 2022

Revision u/s 263 by CIT - having invoking the powers u/s.263 of the Act, no addition on the said issues has been made. The additions have been made on other issues; clearly shows that the issues raised in the proceedings u/s.263 of the Act are unsustainable and liable to be quashed. - AT

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  1. Revision u/s 263 - not making the addition of unpaid service tax is erroneous as well as prejudicial to the interest of the revenue - Order of Pr. CIT on this issue confirmed.

  2. Revision u/s 263 - Invoking revisionary power u/s 263 of the Act is merely on suspicions is untenable. Further, the Ld. PCIT has not made any discussion on the issues...

  3. Revision u/s 263 - Explanation 2(d) under section 263 specifically states that revision is possible only due to judgments of the jurisdictional High Court or supreme...

  4. Revision u/s 263 - The fact remains that the specific issue raised, in the revision order was specifically looked into, detailed submissions were made and these...

  5. Revision u/s 263 - violation of the provisions of section 40A(3) - CIT is not justified in invoking jurisdiction u/s 263 on the strength of an audit note - AT

  6. Revision u/s 263 - power of CIT to revise - return processes u/s 143(1) is not subjected to revision - AT

  7. Revision u/s 263 - the ld PCIT had invoked revision jurisdiction u/s 263 of the Act on the very same point of allowability of LTCL. Hence it could be safely concluded...

  8. Assessment u/s 153A – Invocation of power of revision u/s 263 - Commissioner did not have jurisdiction to initiate any proceedings u/s 263 - HC

  9. Revision u/s 263 - No error in the action of AO in not travelling to other issues for making addition once no addition was made on the issue for which assessment was...

  10. Revision u/s 263 - CIT was clothed with ample supervisory powers to direct for redoing the assessment provided twin conditions as envisaged by Section 263 were fulfilled.

 

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