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“processing under section 143(1)”

Assessment ProceduresSection 143(1)Section 143(1)158 judgments

The decision most relied on for processing under section 143(1) is CIT v. B.N. Bhattacharya & Another (118 ITR 461), cited in 1,656 judgments on BharatTax.

Leading authorities on processing under section 143(1)

CIT v. B.N. Bhattacharya & Another
118 ITR 461 · 1997 · Supreme Court
1,656
citing judgments

Appealing a tax assessment requires more than just filing the appeal; it involves actively pursuing it. The assessee must effectively engage with the appellate process.

CIT v. AIMIL Ltd.
321 ITR 508 · 2010 · High Court
1,629
citing judgments

Employee contributions to PF and ESIC, deposited beyond the due date under the respective Acts but within the due date for filing the income tax return under Section 139(1), are allowable deductions under Section 36(1)(va). Such disallowance cannot be made during processing under Section 143(1).

Checkmate Services Pvt. Ltd. v. CIT
143 Taxmann.com 178 · 2022 · Supreme Court
1,392
citing judgments

Employee contributions to provident fund and ESI deposited by an employer beyond the due dates prescribed under the respective special Acts are not allowable as a deduction under section 36(1)(va) of the Income-tax Act, 1961. Such disallowance can be made during processing under section 143(1).

CIT v. Anil Kumar Bhatia
352 ITR 493 · 2013 · High Court
537
citing judgments

Section 153A can be invoked to reassess income for all years under consideration prior to a search, even if returns for those years were processed under Section 143(1)(a). The Assessing Officer has the power to reassess total income in such cases without fetters.

Asia Satellite Telecommunications Co. Ltd. v. DIT
332 ITR 340 · 2011 · High Court
359
citing judgments

Payments for the use of equipment, such as satellite transponders, do not constitute 'royalty' under Section 9(1)(vi) of the Income-tax Act, 1961, or under applicable tax treaties, especially when there is no transfer of the right to use a process or underlying technology.

DIT v. Ericsson A.B
343 ITR 470 · 2012 · High Court
256
citing judgments

Payments for the use of copyrighted software or reimbursement of data processing costs do not constitute 'royalty' under Section 9(1)(vi) of the Income-tax Act or Article 12(3) of a DTAA where there is no transfer of copyright or rendering of services that "make available" technical knowledge. This position was later upheld by the Supreme Court.

Jiji Varghese v. ITO(TDS) & Ors.
443 ITR 267 · 2022 · High Court
220
citing judgments

Section 234E fee cannot be imposed for periods prior to June 1, 2015. This applies even when the processing of the return under Section 200A(c) occurred before that date.

CIT v. Kotak Securities Ltd.
383 ITR 1 · 2016 · Supreme Court
203
citing judgments

Fees for technical services under Section 9(1)(vii) can include payments for fully automated services even without direct human interface, as modern technological developments blur the specific human element in such processes.

Judgments citing processing under section 143(1)

Gurmeet Singh Hora, Raipur vs. Assistant Commissioner of Income Tax, Circle-1(1), Raipur

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

ITA 45/RPR/2023[2018-19]Status: DisposedITAT Raipur02 Jul 2026AY 2018-19

Bench: Shri Ravish Sood & Shri Arun Khodpiaआयकर अपील सं. / Ita No. 45/Rpr/2023 "नधा"रण वष" / Assessment Year : 2018-19 Gurmeet Singh Hora A-1, Sai Nagar, Raipur (C.G.) Pan : Aaoph6268D .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Centralized Processing Center (Cpc), Bengaluru ……""यथ" / Respondent

For Appellant: Shri R.B Doshi, CAFor Respondent: Shri Satya Prakash Sharma, Sr. DR
Section 143(1)Section 36(1)(va)Section 43B

when a tax auditor indicates a disallowance in the tax audit report, for this indication alone, the expense must be disallowed while processing under section 143(1) by the CPC. It is nevertheless important to bear in mind the fact that a tax audit report is prepared by an independent

Ntt Managed Services India Private Limited, Hyderabad vs. DCIT., Circle-5(1), Hyderabad

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 1165/HYD/2025[2023-24]Status: HeardITAT Hyderabad04 Mar 2026AY 2023-24

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.1165/Hyd/2025 Assessment Year 2023-2024 Ntt Managed Services India Private Limited, The Dcit, Vs. Hyderabad. Telangana. Circle-5(1), Hyderabad. Pin 500 081 Pan Aarcs7517G (Appellant) (Respondent) िनधा"रती "ारा/Assessee By -None- राज" व "ारा/Revenue By : Sri Mathivanan Sa, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 02.03.2026 घोषणा की तारीख/Pronouncement: 04.03.2026 आदेश/Order Per Vijay Pal Rao:

For Respondent: Sri Mathivanan SA, Sr. AR
Section 108(8)Section 143(1)Section 80J

despite the fact that the report was duly uploaded by the Chartered Accountant and was available on record at the time of processing under section 143(1) of the IT Act. Ground No.3 The learned Additional / Joint Commissioner of Income-tax (Appeals) erred in disregarding the judicial precedents cited ... Assessee had accordingly filed its return of income and claimed deduction under section 80JJAA of the IT Act. The ITR was processed under section 143(1) of the IT Act and claim of deduction under section 80JJAA of IT Act had been rejected by CPC for reason that assessee failed

Income Tax Officer Ward-3 Exemp, Nagpur vs. Prerna Samajik Sanskritik Bahuddeshiya Shikshan Sanstha, Armori, Gadchiroli

In the result, the appeal of revenue is accordingly dismissed

ITA 408/NAG/2024[2022-23]Status: DisposedITAT Nagpur25 Feb 2026AY 2022-23

Bench: Shri Pawan Singh, Jm & Shri Khettra Mohan Roy, Am

For Appellant: Shri Milind Bhusari, AdvFor Respondent: Shri Pankaj Kumar, CIT–DR
Section 11Section 119(2)(b)Section 12A(1)(ac)Section 12A(1)(ba)Section 143(1)Section 143(1)(a)Section 2

vide order dated 26-05-2023 under section 119(2)(b) of the Act. With condonation of delay so granted before processing under section 143(1), there was no basis with the 3 ITA No. 408/Nag./2024 Prerna Samajik Sanskritik Bahuddeshiya Shikshan Sanstha CPC for rejection of claim of exemption

Divya Dinesh, Bengaluru vs. DCIT, Circle-7(1)(1), Bangalore

ITA 2195/BANG/2025[2021-22]Status: DisposedITAT Bangalore24 Feb 2026AY 2021-22

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 115BSection 143(1)Section 154Section 250Section 80G

Hence, the assessee declared total income of Rs. 36,78,25,370/- being taxable at special rate only. 4.3 The return was processed under section 143(1) of the Act and intimation order was generated as on 28th February 2020 wherein the CPC, sett of the short-term capital loss ... return of income was filed declaring total taxable income of Rs. 36,78,25,370.00 only. The return was processed under section 143(1) of the Act by CPC, which determined a higher income and raised a tax demand. The difference arose because the CPC did not allow

Divya Dinesh, Bengaluru vs. DCIT, Circle-7(1)(1), Bangalore

In the result appeal of the assessee is allowed

ITA 2194/BANG/2025[2019-2020]Status: DisposedITAT Bangalore24 Feb 2026AY 2019-2020

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Sudheendra B.R, AdvocateFor Respondent: Shri Balusamy N, JCIT
Section 115BSection 143(1)Section 154Section 250Section 80G

Hence, the assessee declared total income of Rs. 36,78,25,370/- being taxable at special rate only. 4.3 The return was processed under section 143(1) of the Act and intimation order was generated as on 28th February 2020 wherein the CPC, sett of the short-term capital loss ... return of income was filed declaring total taxable income of Rs. 36,78,25,370.00 only. The return was processed under section 143(1) of the Act by CPC, which determined a higher income and raised a tax demand. The difference arose because the CPC did not allow

DCIT-2(2)(1), Mumbai vs. Modern Veer Rays Security Force (India) Pvt. Ltd., Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 7886/MUM/2025[2020-21]Status: DisposedITAT Mumbai20 Feb 2026AY 2020-21

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokardcit Circle-2(2)(1) Modern Veer Rays Room No. 417, 4Th Security Force (India) Floor, Aayakar Bhavan, Vs. Pvt. Ltd. Churchgate, M. K. 6Th Floor, Atlanta Road, Mumbai- Centre, Sonawala 400 020 Road, Goregaon East, Mumbai-400 063 Pan/Gir No. Aaacm3692H (Applicant) (Respondent) Revenue By Shri Annavaram Kosuri, Ld. Dr Assessee By Shri Rakesh Joshi, Ld. Ar Date Of Hearing 19.02.2026 Date Of Pronouncement 20.02.2026

Section 143(1)Section 250Section 36(1)(va)Section 38

terminus powers with that of the Assessing Officer and is empowered to examine the material placed on record. It was argued that processing under section 143(1) is purely based on audit report entries and the assessee had no opportunity to explain the factual position before CPC. Therefore, there

Tml Benefit Trust, Mumbai vs. ITO Ward 30(1)(1), Mumbai

In the result: (i) The appeal against the adjustment under section 143(1)

ITA 7826/MUM/2025[2018-19]Status: DisposedITAT Mumbai20 Feb 2026AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 10(34)Section 115Section 143(1)Section 143(1)(a)Section 143(3)

assessee-trust from Tech Mahindra Limited (“TML”) during Assessment Year 2018–19 and the legality of its disturbance at the stage of processing under section 143(1) of the Income-tax Act, 1961 (“the Act”), despite the very 143(3). One appeal relates to the quantum assessment order passed under ... reflected the same in the appropriate schedule of the return, particularly in Schedule BP as exempt income. 4. The return was processed under section 143(1). While processing, CPC made an adjustment treating the claim as an “incorrect claim” within the meaning of section 143(1)(a)(ii), primarily

Tml Benefit Trust, Mumbai vs. ITO 30(1)(1), Mumbai

In the result: (i) The appeal against the adjustment under section 143(1)

ITA 7756/MUM/2025[2018-19]Status: DisposedITAT Mumbai20 Feb 2026AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 10(34)Section 115Section 143(1)Section 143(1)(a)Section 143(3)

assessee-trust from Tech Mahindra Limited (“TML”) during Assessment Year 2018–19 and the legality of its disturbance at the stage of processing under section 143(1) of the Income-tax Act, 1961 (“the Act”), despite the very 143(3). One appeal relates to the quantum assessment order passed under ... reflected the same in the appropriate schedule of the return, particularly in Schedule BP as exempt income. 4. The return was processed under section 143(1). While processing, CPC made an adjustment treating the claim as an “incorrect claim” within the meaning of section 143(1)(a)(ii), primarily

Bhartiya Aadarsh Shikshan Samiti, Mandsaur vs. DCIT (Exemption), Bhopal

Appeal is allowed for statistical purpose, subject

ITA 612/IND/2025[2018-19]Status: DisposedITAT Indore19 Feb 2026AY 2018-19

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 11Section 12ASection 12A(2)Section 139Section 139(4)Section 143(1)

IN THE INCOME TAX APPELLATE TRIBUNAL INDORE BENCH, INDORE BEFORE SHRI B.M. BIYANI, ACCOUNTANT MEMBER AND SHRI PARESH M. JOSHI

Aditya Birla Sun Life Amc Limited, Maharashtra vs. The Deputy Commissioner of Income Tax- Circle 6(1)(1), Maharashtra

ITA 6703/MUM/2025[2023-24]Status: DisposedITAT Mumbai06 Feb 2026AY 2023-24

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. Ita No. 6663/Mum/2025 (Assessment Year: 2017-18) 2. Ita No. 6701/Mum/2025 (Assessment Year: 2018-19) 3. Ita No. 6702/Mum/2025 (Assessment Year: 2022-23) & 4. Ita No. 6703/Mum/2025 (Assessment Year: 2023-24) Aditya Birla Sun Life Dcitcircle-6(1)(1), Amc Limited, Room No. 502, 5Th 17Th Floor, One World Vs. Floor, Aayakar Centre Tower-1, Jupiter Bhavan, M. K. Mill Compount, 841, Road, Churchgate, Senapati Bapat Marg, Mumbai-400 020 Delisle Road, S.O. Mumbai-400 013 Pan/Gir No. Aaacb6134D (Applicant) (Respondent) Assessee By Shri Ronak Doshi, Shri Shrey Agrawal & Shri Aadish Jain, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 27.01.2026 Date Of Pronouncement 06.02.2026

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 36(1)(va)Section 40Section 43B

assessee filed its returns of income electronically declaring income under the normal provisions of the Act. The returns were initially processed under section 143(1) of the Act. Subsequently, the cases of the assessee were selected for scrutiny through Computer Aided Scrutiny Selection (CASS).Statutory notices under section 143 ... order passed under section 143(3) read with section 144B of the Act. The CIT(A) recorded that only the income as processed under section 143(1) had been adopted in the assessment order and, accordingly, dismissed the appeal. 9. In A.Y. 2023–24, the Assessing Officer made an addition

Aditya Birla Sun Life Amc Limited, Maharashtra vs. The Deputy Commissioner of Income Tax-Circle 6(1)(1), Maharashtra

ITA 6702/MUM/2025[2022-23]Status: DisposedITAT Mumbai06 Feb 2026AY 2022-23
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 36(1)(va)Section 40Section 43B

assessee filed its returns of income electronically declaring income under the normal provisions of the Act. The returns were initially processed under section 143(1) of the Act. Subsequently, the cases of the assessee were selected for scrutiny through Computer Aided Scrutiny Selection (CASS).Statutory notices under section 143 ... order passed under section 143(3) read with section 144B of the Act. The CIT(A) recorded that only the income as processed under section 143(1) had been adopted in the assessment order and, accordingly, dismissed the appeal. 9. In A.Y. 2023-24, the Assessing Officer made an addition

Aditya Birla Sun Life Amc Limited, Maharashtra vs. The Deputy Commissioner of Income Tax- Circle 6 (1)(1), Maharashtra

Accordingly, this ground is allowed

ITA 6701/MUM/2025[2018-19]Status: DisposedITAT Mumbai06 Feb 2026AY 2018-19
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 36(1)(va)Section 40Section 43B

assessee filed its returns of income electronically declaring income under the normal provisions of the Act. The returns were initially processed under section 143(1) of the Act. Subsequently, the cases of the assessee were selected for scrutiny through Computer Aided Scrutiny Selection (CASS).Statutory notices under section 143 ... order passed under section 143(3) read with section 144B of the Act. The CIT(A) recorded that only the income as processed under section 143(1) had been adopted in the assessment order and, accordingly, dismissed the appeal. 9. In A.Y. 2023-24, the Assessing Officer made an addition

Aditya Birla Sun Life Amc Limited, Maharashtra vs. The Deputy Commissioner of Income Tax Circle 6(1)(1), Maharashtra

Accordingly, this ground is allowed

ITA 6663/MUM/2025[2017-18]Status: DisposedITAT Mumbai06 Feb 2026AY 2017-18
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 144BSection 250Section 270ASection 36(1)(va)Section 40Section 43B

assessee filed its returns of income electronically declaring income under the normal provisions of the Act. The returns were initially processed under section 143(1) of the Act. Subsequently, the cases of the assessee were selected for scrutiny through Computer Aided Scrutiny Selection (CASS).Statutory notices under section 143 ... order passed under section 143(3) read with section 144B of the Act. The CIT(A) recorded that only the income as processed under section 143(1) had been adopted in the assessment order and, accordingly, dismissed the appeal. 9. In A.Y. 2023-24, the Assessing Officer made an addition

Vishva Kalyan Foundation, Surendranagar vs. ITO Ward 2 Exempetion Ahmedabad, Ahmedaabd

In the result, the appeal of the assessee is allowed

ITA 1992/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad30 Jan 2026AY 2020-21

Bench: Shri Siddhartha Nautiyal & Smt. Annapurna Gupta

For Appellant: Shri Gaurang Khakhkhar, CAFor Respondent: Shri Rameshwar P Meena, SR-DR
Section 143(1)Section 154

both the return of income and Form No. 10B were e-filed on 30-03-2021. The return was processed under section 143(1) only on 30-11-2021, much after Form No. 10B had already been uploaded and was available on the Departmental system. The assessee filed rectification applications ... such delay. The Tribunal also observed that treating issues such as corpus donation or denial of exemption on technical grounds while processing under section 143(1) travels beyond the permissible scope of prima facie adjustments contemplated in that provision. 12. In Barwala Panjrapole (supra), the Tribunal reiterated that where Form

Kapila Mahendra Patel, Vadodara vs. The Dy. CIT, Circle-1(1)(1), Vadodara

The appeal of the assessee is allowed for statistical purposes

ITA 1905/AHD/2025[2024-25]Status: DisposedITAT Ahmedabad19 Jan 2026AY 2024-25

Bench: Shri Siddhartha Nautiyal & Shri Narendra Prasad Sinhaिनधा"रणवष"/Assessment Year: 2024-25 Kapila Mahendra Patel Vs. The Dy.Cit Circle-1(1)(1) Kamdhenu Estate Aayakar Bhavan Opp. Citi Bank Race Course Race Course Circle Vadodara – 390 007 Vadodara – 390 007 Pan : Adbpp 3883 G अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Hemant Suthar, Ar Revenue By : Shri Rameshwar P. Meena, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 13/01/2026 घोषणा की तारीख /Date Of Pronouncement: 19/01/2026

For Appellant: Shri Hemant Suthar, ARFor Respondent: Shri Rameshwar P. Meena, Sr.DR
Section 143(1)Section 143(1)(a)Section 24Section 250

hands of the other co-owners. These aspects have not been examined either by the CPC at the time of processing under section 143(1) of the Act or by the CIT(Appeals) at the first appellate stage, who proceeded solely on the basis of the ownership percentage reflected

Smt. Raj Bala, Chandigarh vs. DCIT/ACIT Circle 1(1), Chandigarh

In the result, the appeal of the assessee is treated as allowed for statistical purposes

ITA 1142/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh14 Jan 2026AY 2020-21

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Tejmohan Singh, AdvocateFor Respondent: Smt. Geetinder Mann, CIT DR
Section 139(1)Section 143(1)Section 2(24)(x)Section 36(1)(va)Section 43B

debatable issue whether the delayed payment towards employees share in EPF/ESI is deductible or not which is beyond the scope of processing under section 143(1) and as such the disallowance made is illegal, unjustified and arbitrary. 3. Briefly, the facts of the case are that the assessee is engaged

Sterling Court F Wing Co -Op. Housing Society Limited, Mumbai vs. Income Tax Officer Ward 31(2)(1), Mumbai

ITA 7121/MUM/2025[2012-13]Status: DisposedITAT Mumbai08 Jan 2026AY 2012-13

Bench: Shri Pawan Singh, Jm &

For Appellant: ITA Nos. 7121, 7120 &
Section 139(1)Section 143(1)Section 143(1)(a)Section 154Section 80ASection 80A(5)Section 80PSection 80P(2)(d)

after claiming deduction under Chapter-VIA as per provisions of section 80P(2)(d) of the Act. The return of assessee was processed under section 143(1) on 27.02.2013, disallowing the claim of deduction under section 80P(2)(d) for Rs. 2,66,556/-. Being aggrieved with such disallowance, assessee

Aquila Heights Apartment Owners Association, Bangalore vs. Dc/ACIT, Circle-6(1)(1), Bangalore

ITA 2026/BANG/2025[2016-17]Status: DisposedITAT Bangalore05 Jan 2026AY 2016-17

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Section 143(1)Section 154

1) of the Act involves issues that require detailed examination and verification, therefore, such an adjustment falls outside the permissible scope of processing under section 143(1) and is not legally sustainable. 7. Without prejudice to the above grounds, that the learned assessing officer ought to have considered the surplus

Granules India Limited, Hyderabad vs. DCIT., Circle-2(1), Hyderabad

In the result, the appeal filed by the assessee company is allowed

ITA 1295/HYD/2025[2020-21]Status: DisposedITAT Hyderabad24 Dec 2025AY 2020-21

Bench: Shri Manjunatha G & Shri Ravish Soodआ.अपी.सं /Ita No.1295/Hyd/2025 (िनधा"रण वष"/Assessment Year:2020-21) M/S. Granules India Limited, Dy. Commissioner Of Income Vs. Hyderabad. Tax, Pan : Aaacg7369K Circle 2(1), Hyderabad. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Y.V. Bhanu Narayan Rao, C.A. राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr-Dr सुनवाई की तारीख/Date Of Hearing: 22/12/2025 घोषणा की तारीख/Pronouncement: 24/12/2025

For Appellant: Shri Y.V. Bhanu Narayan RaoFor Respondent: Dr. Sachin Kumar, SR-DR
Section 139(1)Section 143(1)Section 143(3)Section 154Section 155(18)Section 270A

claiming a refund of Rs. 1,77,09,020/-. The return of income filed by the assessee company was processed under Section 143(1) of the Act, dated 24/12/2021, by the AP/CPC, Bengaluru, wherein its income was determined at Rs. 532,16,26,070/-. 3. Thereafter, the AO framed ... approx.), against which it had raised a claim of refund of Rs. 1.77 crores (approx.). The said return of income was thereafter processed under Section 143(1) of the Act on 24/12/2021, determining the income of the assessee company at Rs. 532.16 crores (approx.), against which a demand

Electronics & Quality Development Centre, Gandhinagar vs. The Dy.CIT, (Exemption), Circle-1, Ahmedabad

In the result, the appeal filed by the assessee is allowed

ITA 248/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad22 Dec 2025AY 2022-23

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri Sanjay R Shah, CAFor Respondent: Shri R. P. Rastogi, CIT-DR
Section 11Section 139(1)Section 139(5)Section 143Section 143(1)Section 143(1)(a)

inherently debatable. Therefore, exemption under section 11 cannot be denied on such a purely technical ground, particularly at the stage of processing under section 143(1). The Counsel also drew attention to the grave prejudice caused to the assessee Electronics & Quality Development Centre vs. DCIT(E) Asst.Year ... Therefore, the action of the CPC in ignoring the audit report and denying exemption under section 11 at the stage of processing under section 143(1) was clearly beyond the scope of permissible adjustments under section 143(1)(a) of the Act. We further find that the learned CIT(Appeals