Revision u/s 263 - Revision based on Audit Objection - a ...

PCIT cannot mechanically revise orders u/s 263 based solely on audit objections; independent findings are essential.

August 26, 2022

Case Laws Income Tax AT

Revision u/s 263 - Revision based on Audit Objection - a mechanical exercise of revisionary powers u/s 263 by the Revisionary Authority by merely citing the Audit Objection cannot be said to be a valid exercise of Revisionary Powers. - PCIT is require to give an independent finding considering the record. The error in the order of the AO, that too such an error which is prejudicial to the interests of the Revenue, has to be pointed out by the Revisionary Authority in the order. The onerous power cannot be exercised mechanically and arbitrarily. - AT

View Source

← Previous Next →

Revision u/s 263 - Revision based on Audit Objection - a ...

PCIT cannot mechanically revise orders u/s 263 based solely on audit objections; independent findings are essential.

August 26, 2022

Case Laws Income Tax AT

You may also like:

Invocation of Section 263 by the Principal Commissioner of Income-Tax (PCIT), alleging non-application of mind and lack of jurisdiction. The key points are: The...

The Appellate Tribunal considered a case involving a revision u/s 263 due to discrepancies in the assessment order, including undisclosed TDS, differences in purchases...

CIT allowed to invoke Section 263 to revise assessment order due to AO's failure to verify assessee's explanation regarding investment in mutual funds/shares despite...

Revision u/s 263 - revision based on the audit objection - borrowed satisfaction - The ITAT noted that the AO had called for details and evidence from the appellant and...

The ITAT quashed the CIT's revision order under section 263, finding it was improperly based solely on audit objections without independent examination of records. The...

Revision u/s 263 by CIT - Merely on the basis of audit objection powers u/s 263 could not have been exercised. The impugned order u/s 263, does not indicate that the...

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...

Rectification of mistake u/s 154 - AO issued notice u/s 154 based on audit objections, adding waiver of principal amount and revising book profit. Tribunal dismissed...

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...

Revision u/s 263 - Being conscious of the fact that the original assessment order could not be revised under section 263 of the Act due to bar of limitation, as provided...

The Appellate Tribunal examined the validity of an order passed u/s 143(3) by the Assessing Officer (AO), which was revised by the Principal Commissioner of Income Tax...

Validity of an ex-parte revisionary order passed by the Principal Commissioner of Income Tax (PCIT) u/s 263 of the Income Tax Act. The key points are: The PCIT passed...

Revision u/s 263 regarding claim of accommodation entry - reliance on statements of third parties. Timelines for completing assessment u/s 143(3). Assessing officer duly...

The case pertains to the reopening of assessment u/s 147, where the reasons recorded were based on audit objections raised by the internal audit party regarding...

Addition on failure to show the “gitty’ expenses in Closing Stock or WIP - addition based on audit objection - goods in transit - the AO passed the order in haste and it...

Quick Updates: