This compilation indexes twelve income-tax rulings pronounced between October 2025 and May 2026 that engage Section 263 of the Income-tax Act, 1961 — the provision conferring revisionary jurisdiction on the Principal Commissioner or Commissioner of Income Tax. The rulings span the Bombay, Madras, Gujarat, Karnataka, and Delhi High Courts as well as the Income Tax Appellate Tribunal, Mumbai, and cover a range of assessee profiles including charitable trusts, listed companies, foreign entities, and state corporations. It is intended for use by in-house tax teams, Big-4 associates, and law-firm researchers who need a quickly navigable digest of recent judicial activity on this provision.

Research index only. This page reproduces case identifiers, bench details, and source-preview observations for research and citation-tracking purposes. Nothing on this page constitutes legal advice, tax advice, or a recommendation of any course of action. Verify every ruling against the full text of the judgment before relying on it.

The statutory framework in one paragraph

Section 263 of the Income-tax Act, 1961 empowers the Principal Commissioner or Commissioner of Income Tax to call for and examine the record of any proceeding under the Act and, if satisfied that any order passed by an Assessing Officer is erroneous in so far as it is prejudicial to the interests of the Revenue, to pass an order modifying, enhancing, cancelling, or directing fresh assessment. The twin conditions — that the order must be (i) erroneous and (ii) prejudicial to the interests of the Revenue — are both conjunctively required; the absence of either condition is fatal to the exercise of jurisdiction. The provision also prescribes a limitation period within which the revisionary order must be passed and mandates an opportunity of hearing before any adverse order is made.

The 12 rulings

1. Commissioner Of Income Tax Exemptions vs Impact Foundation India Ay 2017-18

Bench: Bombay High Court
Date: 4 May 2026
Sections engaged: 263, 11(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal was filed by the Appellant-Revenue under Section 260A of the Income-tax Act, 1961 before the Bombay High Court, challenging the impugned order dated 2nd January 2023. The source preview indicates that the CIT (Exemptions) had exercised revisionary jurisdiction and the text notes the two-limb test applicable to a revision — that the AO's order must be erroneous and that prejudice must be caused to the interests of the Revenue — with the proceeding concerning a charitable entity and amounts totalling Rs. 6,00,00,000 applied towards specified objects per a Board Resolution dated 29 September 2016.

2. Dy. Commissioner Of Income (Int Tax) - vs Mfe Formwork Technology Sdn. Bhd

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 4 May 2026
Sections engaged: 263, 9(1)(i)
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal before the ITAT Mumbai pertains to Assessment Year 2022-23 and involves MFE Formwork Technology SDN BHD (PAN: AAGCM4280M), a company incorporated under the laws of Malaysia and a tax resident there. The source preview indicates that the assessee's Indian subsidiary acts as a Dependent Agent Permanent Establishment (DAPE) or business connection in India, and the matter engages questions of income attribution and taxability in connection with the provisions of the DTAA and Section 9(1)(i), with Section 263 invoked in the context of the earlier assessment of the foreign entity's India-sourced income.

3. Dilip Patel vs The Principal Commissioner Of Income

Bench: Gujarat High Court
Date: 1 May 2026
Sections engaged: 143(3), 153C, 263, 269S, 271D
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter was heard by the Gujarat High Court in Special Civil Application Nos. 4314 and 4316 of 2026, reserved on 27 April 2026. The source preview records the assessee's submission that the satisfaction note in the case of both the buyer and the petitioner reflected the full amount of Rs. 39.32 crores, and that it was only during the assessment that the Assessing Officer called for a DVO report arriving at Rs. 28.50 crores; the assessee contended it was therefore incorrect to hold the AO had erred in not taking the higher figure. The source preview further notes that in the case of the buyers the assessment was never undertaken and that buyers had challenged notices under Section 153C, making the factual foundation for the revision contested.

4. M/S Cognizant Technology vs The Income Tax Officer (TDS) /

Bench: Madras High Court
Date: 28 April 2026
Sections engaged: 10B, 195, 201(1), 202, 260A, 263, 40(a), 9(1), 9(1)(vi)
Outcome: Outcome not specified in source
Procedural / substantive ground: These are Tax Case Appeals Nos. 651 to 653 of 2016 filed under Section 260A of the Income-tax Act, 1961 before the Madras High Court against the common order dated 9 June 2014 passed by the Income Tax Appellate Tribunal, Chennai "C" Bench, in ITA Nos. 1535/Mds/2009, 1536/Mds/2009, and 460/Mds/2010. The source preview states that the appeals relate to a batch of six statutory appeals before the Commissioner of Income Tax (Appeals) and that Section 263 is among the sections cited in the context of this multi-issue TDS and income-characterisation dispute.

5. Asian Paints Limited,Mumbai vs Deputy Commissioner Of Income-Tax

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 28 April 2026
Sections engaged: 263
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 3489/MUM/2025) was filed by Asian Paints Limited (PAN: AAACA3622K) before the ITAT Mumbai and pertains to Assessment Year 2021-22. The source preview indicates that the appeal is directed against an order of the Pr. Commissioner of Income Tax, Mumbai-3, bearing order no. ITBA/REV/F/REV5/2024-25/1074837702(1) dated 21.03.2025, passed against the underlying assessment order dated 29.12.2022; the source preview further notes that the PCIT had perused the records of the assessment and noted that certain issues were not examined thoroughly, which appears to have formed the basis for invoking the revisionary jurisdiction.

6. Kerala Roadways (P) Ltd vs The Dy. Commissioner Of Income

Bench: Madras High Court
Date: 7 April 2026
Sections engaged: 158, 143, 263
Outcome: Outcome not specified in source
Procedural / substantive ground: These are Tax Case Appeal Nos. 373 and 1026 of 2009 and 274 of 2014 filed under Section 260A of the Income-tax Act, 1961 before the Madras High Court. The source preview records that T.C.(A) No. 373 of 2009 challenges the ITAT Chennai order dated 30.01.2009 in IT(SS)A No. 87/MDS/2007 for the block assessment period from 01.04.1996 to 31.03.2002 and 01.04.2002 to 22.01.2003, while T.C.(A) No. 1026 of 2009 challenges the ITAT "B" Bench order dated 18.07.2008 in IT(SS)A No. 47/MDS/2007; the PAN of Kerala Roadways Limited in that appeal is recorded as AAACK1388P. Section 263 arises in the context of these block-assessment proceedings alongside Section 158.

7. Terrier Security Services India vs The Deputy Commissioner Of Income-Tax

Bench: Karnataka High Court
Date: 24 February 2026
Sections engaged: 263
Outcome: Outcome not specified in source
Procedural / substantive ground: This writ petition (W.P. No. 4667 of 2026) was filed under Article 226 of the Constitution of India before the Karnataka High Court. The source preview records that the petitioner sought a direction to the respondents to forthwith refund an amount of Rs. 1,98,358/- that had been recovered, with the respondents including the Deputy Commissioner of Income Tax, Central Circle 2(1), Bangalore, the Principal Commissioner of Income Tax, Central Circle, Bangalore, the Centralized Processing Center, Bengaluru, and the Director General of Income Tax (Systems), New Delhi. The invocation of Section 263 appears in the procedural context of this recovery and refund dispute.

8. The Pr. Commissioner Of Income Tax 25 vs Milestone Real Estate Fund

Bench: Bombay High Court
Date: 19 January 2026
Sections engaged: 263
Outcome: Outcome not specified in source
Procedural / substantive ground: This Income Tax Appeal No. 3056 of 2019 was filed by the Revenue before the Bombay High Court challenging the order dated August 10, 2018 passed by the Income Tax Appellate Tribunal, Mumbai "I" Bench. The source preview states that by the impugned ITAT order the Tribunal had quashed and set aside the order that is the subject of the present appeal. A notable procedural feature recorded in the preview is that between the final hearing date (7 January 2026) and the date of pronouncement (19 January 2026) the bench assignments changed and the 2019 appeals were no longer formally assigned to the same bench; however, with the consent of both parties, the bench proceeded to pass the order.

9. The Commissioner Of Income Tax vs M/S. Cognizant Technology Solutions

Bench: Madras High Court
Date: 19 December 2025
Sections engaged: 147, 148, 263
Outcome: Outcome not specified in source
Procedural / substantive ground: This is T.C.A. No. 224 of 2014 filed by the Revenue before the Madras High Court under Section 260-A of the Income-tax Act against the order of the Income Tax Appellate Tribunal, Madras "C" Bench, Chennai dated 10.02.2012 passed in ITA No. 1921/Mds/2010, with questions of law admitted on 22.08.2014. The source preview records that the assessment had been the subject of a suo motu revision under Section 263, pursuant to which the Commissioner of Income Tax set aside the assessment to the extent of the determination of the computation of exemption under Section 10B of the Act, with the claim of depreciation also identified as a subject matter in the revision.

10. Jangli (Since Deceased) Thr His Legal vs The State & Ors

Bench: Delhi High Court
Date: 10 December 2025
Sections engaged: 299, 263
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter (FAO 259/2015 and LA.APP. 500/2015) was filed before the Delhi High Court as an appeal under Section 299 of the Indian Succession Act, 1925 read with Section 104 of the Code of Civil Procedure, 1908, by the legal heirs of the original petitioner Jangli in MPC No. 21/2006, aggrieved by a judgment dated 28.08.2004 of the Additional District Judge (Central), Delhi, by which a Letter of Administration granted in favour of the petitioner was revoked. The source preview and sections cited indicate that Section 263 as listed pertains to the Indian Succession Act context of this proceeding; researchers should review the full judgment to confirm the precise statutory regime before treating this as an income-tax Section 263 ruling.

11. CIT (Exemptions), Mumbai vs Sir Kikabhai Premchand Settlement

Bench: Bombay High Court
Date: 25 November 2025
Sections engaged: 11, 263
Outcome: Outcome not specified in source
Procedural / substantive ground: This Income Tax Appeal No. 2328 of 2018 was filed under Section 260-A of the Income-tax Act, 1961 by the Appellant-Revenue before the Bombay High Court, impugning the ITAT order dated 27 December 2017 passed in Income Tax Appeal No. 779/MUM/2017 for Assessment Year 2012-13, which had dismissed the Revenue's appeal. The source preview records that the ITAT had followed an earlier decision of its Co-ordinate Bench in the assessee's own case; the assessee (PAN: AABTS7221E) is a settlement trust and the appeal concerns the intersection of Section 11 (income of charitable or religious trusts) and the revisionary jurisdiction exercised under Section 263.

12. M/S Karnataka State Beverages vs National Faceless Assessment Centre

Bench: Karnataka High Court
Date: 27 October 2025
Sections engaged: 143(3), 263, 144B
Outcome: Outcome not specified in source
Procedural / substantive ground: This writ petition (W.P. No. 19946 of 2021) was filed under Articles 226 and 227 of the Constitution of India before the Karnataka High Court. The source preview records that the petitioner sought to quash the assessment order passed by the National Faceless Assessment Centre under Section 143(3) read with Section 263 read with Section 144B of the Income-tax Act, 1961, dated 29.09.2021, with the respondents being the National Faceless Assessment Centre (New Delhi) and the Deputy/Assistant Commissioner of Income Tax, Circle 4(1)(1), Bengaluru.

Patterns across these 12 rulings

Revision invoked across diverse assessee profiles. Across the cases in this compilation, Section 263 has been invoked against entities as varied as charitable trusts and settlement trusts (cases 1 and 11), a listed manufacturing company (case 5), a foreign entity with India-sourced income (case 2), a state corporation (case 12), and transport companies under block-assessment regimes (case 6). This breadth signals that revisionary jurisdiction is not confined to any particular industry or entity type.
Multi-forum lifecycle is a recurring feature. Several rulings in this set represent the third or fourth judicial forum to examine the same underlying assessment — beginning with the AO, proceeding to the revisionary authority under Section 263, then to the ITAT, and finally to the High Court under Section 260A. Cases 4, 6, 8, 9, and 11 each reflect this multi-tier trajectory, underscoring the extended litigation lifecycle that Section 263 proceedings can generate.
Adequacy of examination by the AO as a recurring flashpoint. The source preview for case 5 (Asian Paints) specifically records that the PCIT noted "certain issues were not examined thoroughly" as the basis for invoking revision, and the source preview for case 3 (Dilip Patel) shows the assessee contesting whether the AO's approach to the valuation amount was in fact erroneous. The question of whether mere inadequacy of inquiry — as distinct from a positively wrong order — is sufficient to satisfy the twin conditions for exercise of revisionary jurisdiction appears as a contested issue across multiple cases.
Intersection with other provisions. No case in this compilation engages Section 263 in isolation. The provisions that co-appear most frequently include Section 143(3) (scrutiny assessment), Section 11 and 11(2) (charitable income), Section 9(1)(i) (income deemed to accrue in India), and Section 153C (search-related assessments). This pattern confirms that Section 263 proceedings almost always arise in the wake of a substantive assessment dispute under another provision.
Outcome data is unavailable across all 12 rulings. Every case in this compilation carries the outcome notation "Outcome not specified in source." Researchers should treat this compilation as a citation-tracking and issue-spotting tool only, and must access the full text of each judgment to determine the operative holding, any stay, or subsequent reversal.

How to use this compilation

This compilation is organised to help researchers quickly identify which courts and tribunals have recently heard Section 263 disputes, what co-provisions were engaged, and what procedural posture the cases were in at the time of the order. To use it effectively, start by filtering on the "Sections engaged" line to locate cases closest to your research question — for example, if you are researching a charitable trust revision, cases 1 and 11 are the most directly relevant starting points, while case 12 is relevant for faceless assessment proceedings. The bench and date fields allow you to sequence the rulings chronologically and to identify whether a High Court ruling was preceded by an ITAT ruling on the same or related facts.

Before citing any ruling from this index in a brief, opinion, or submission, you must obtain and read the full text of the judgment from the source portal (indiankanoon.org or the relevant High Court's official judis portal). The text previews reproduced here are partial extracts only and do not capture the dispositive portion of the judgment. In particular, since every outcome in this compilation is listed as "Outcome not specified in source," the substantive holding — including whether the Section 263 order was upheld, quashed, or remanded — is not determinable from this index alone.

Finally, check for subsequent developments: a High Court ruling may have been appealed to the Supreme Court, a stay may have been granted, or a CBDT instruction may have been issued on a related point after the date of the order. Cross-reference the citation against the Supreme Court's cause-list database and the CBDT's circular repository before treating any ruling as settled law on the point you are researching.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 263 Revision Powers: 12 Recent ITAT and HC Rulings (2025–2026)