Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights October 2022 Year 2022 This

Scope of appeal before CIT(A) after revision order u/s 263 - ...


Assessees can appeal AO additions directed by PCIT u/s 263, but not the legality of Section 143(3)/153C orders.

October 6, 2022

Case Laws     Income Tax     AT

Scope of appeal before CIT(A) after revision order u/s 263 - Since, pending proceedings before the Ld.CIT(A) is with reference to additions made in pursuant to directions of the PCIT, in our considered view, the assessee can only challenge additions made by the AO in pursuant to directions of the PCIT in 263 proceedings on merits, but the assessee cannot question the legality or otherwise of assessment order passed by the AO u/s.143(3) r.w.s.153C of the Act, in pursuant to search action u/s.132 of the Act. - AT

View Source

 


 

You may also like:

  1. 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...

  2. The ITAT upheld the Revision u/s 263 by PCIT, finding the AO's assessment under section 143(3) r.w.s. 153C erroneous and prejudicial to Revenue. The unsigned assessment...

  3. The High Court held that the Principal Commissioner of Income Tax (PCIT) lacked jurisdiction to pass an order u/s 263 of the Income Tax Act in this case. The Assessing...

  4. 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...

  5. The Appellate Tribunal held that the issues on which the reassessment order was passed u/s 147 read with Section 143(3) and the issues on which the revision order was...

  6. ITAT ruled against Principal CIT's revision under Section 263, finding the order procedurally flawed. The tribunal held that PCIT cannot delegate verification...

  7. The crux of the case revolves around the applicability of Section 69A read with Section 115BBE of the Income Tax Act on the addition made by the Assessing Officer (AO)...

  8. Assessment u/s 153C versus 143 - Additions u/s 45 - Underreporting of sale consideration for immovable property while framing the Assessment Order u/s 143(3) - Whether...

  9. 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...

  10. Revision u/s 263 - assessment order as contrary to the draft assessment order - The remedy against unjust disallowances, on merits, lies in the appellate process and not...

  11. 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...

  12. Revision u/s 263 - Validity of order of ITAT, cancelling the order of assessment u/s 115 WE(3) and directing the assessing officer to make an order de novo only for the...

  13. 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...

  14. Revision u/s 263 - receipt of on-money - incriminating material found in search or not? - PCIT should himself have conducted the enquiry or causing to make such...

  15. The ITAT Jaipur addressed a case involving a revision u/s 263 concerning the addition u/s 68 based on a report from an investigation in Mumbai. The PCIT contended that...

 

Quick Updates:Latest Updates