#Revisionary Powers

The ITAT Surat has ruled that the Principal CIT cannot use Section 263 to reopen an assessment already concluded under Section 147 if the AO conducted a thorough scrutiny, accepted the assessee’s return, and no evidence of revenue loss was established. This reinforces that revisionary powers are not a substitute for proper reassessment and protects taxpayers from arbitrary re-litigation after full adjudication.

ITAT Ahmedabad rules that Corporate Social Responsibility (CSR) expenses cannot be added back to 'book profit' for Minimum Alternate Tax (MAT) calculations under Section 115JB. The tribunal also clarifies that Section 14A disallowance for exempt income does not apply when tax liability is computed under MAT, offering relief to taxpayers facing revisionary proceedings.

ITAT Dehradun rules that revisionary powers under Section 263 of the Income Tax Act cannot be invoked merely to substitute the Assessing Officer's opinion unless a material error is established. The Tribunal quashed the PCIT's order, emphasizing that the AO's acceptance of loan details after due inquiry cannot be overturned without evidence of prejudice to revenue or procedural lapse.

ITAT Pune rules that the Commissioner's revisionary powers under Section 263 IT Act cannot be invoked to reassess depreciation on goodwill or warranty provisions already correctly allowed by the Assessing Officer. The ruling underscores that revisionary jurisdiction requires evidence of erroneous or prejudicial orders, not mere re-examination of settled claims.

ITAT Delhi quashes PCIT's revision under Section 263 for relying on incorrect appreciation of balance sheet entries and change of opinion, reinforcing that lack of inquiry-not inadequate inquiry-triggers revisionary powers.