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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)

Rajesh Kumar Garg, Delhi vs. ACIT, Circle-49(1), Delhi

ITA 970/DEL/2025[2020-21]Status: DisposedITAT Delhi22 Aug 2025AY 2020-21

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishra

Section 139(1)Section 143(1)Section 2(24)(x)Section 36(1)(iv)Section 36(1)(va)Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH 'E': NEW DELHI BEFORE SHRI YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI

Gurudwara Shri Guru Singh Sabha, Delhi vs. ITO (Exemption) Ward 1(2), Delhi

In the result, the appeal of the assessee in ITA No

ITA 1878/DEL/2025[2020-21]Status: DisposedITAT Delhi22 Aug 2025AY 2020-21

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Pranshu Singhal, CAFor Respondent: Shri Manish Gupta, Sr. DR
Section 11Section 143(1)

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘G’ BENCH, NEW DELHI BEFORE MS. MADHUMITA ROY, JUDICIAL MEMBER, AND SHRI NAVEEN

M/S Pramod Telecom Pvt.Ltd., Lucknow vs. DCIT/ACIT-3, Lucknow

In the result, in ITA. No

ITA 243/LKW/2022[2020-21]Status: DisposedITAT Lucknow19 Aug 2025AY 2020-21

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Rakesh Garg, AdvocateFor Respondent: Sh. Deepak Yadav, DR
Section 143(1)Section 143(1)(a)Section 143(3)Section 154Section 250Section 36(1)(va)Section 43B

facts of the case are that the assessee company filed a return of income on 30.10.2018 which was processed under section 143(1)(a) vide order dated 2.10.2019 at a total income of Rs. 76,82,700/- by making the following adjustments:- i. Inconsistency in provision of payment of gratuity ... assessee filed an appeal before the ld. CIT(A), NFAC. Before the ld. CIT(A), it was submitted that during the processing under section 143(1), an addition of Rs.78,34,183/- was made on account of some inconsistency noticed in the provisions for payment of gratuity under section

M/S Pramod Telecom Pvt.Ltd., Lucknow vs. DCIT/ACIT-3, Lucknow

In the result, in ITA. No

ITA 242/LKW/2022[2018-19]Status: DisposedITAT Lucknow19 Aug 2025AY 2018-19

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Rakesh Garg, AdvocateFor Respondent: Sh. Deepak Yadav, DR
Section 143(1)Section 143(1)(a)Section 143(3)Section 154Section 250Section 36(1)(va)Section 43B

facts of the case are that the assessee company filed a return of income on 30.10.2018 which was processed under section 143(1)(a) vide order dated 2.10.2019 at a total income of Rs. 76,82,700/- by making the following adjustments:- i. Inconsistency in provision of payment of gratuity ... assessee filed an appeal before the ld. CIT(A), NFAC. Before the ld. CIT(A), it was submitted that during the processing under section 143(1), an addition of Rs.78,34,183/- was made on account of some inconsistency noticed in the provisions for payment of gratuity under section

Singularity Labs Private Limited, Gandhinagar vs. The ITO, Ward-4(1)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 423/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad14 Aug 2025AY 2019-20

Bench: Ms.Suchitra R. Kamble & Shri Makarand V.Mahadeokarasstt.Year : 2019-2020 Singularity Labs Private Limited Ito, Ward-4(1)(1) A Wing, Unit No.105 Vs. Ahmedabad- 380 Building No.1-A, Aqualine Properties 015. Pvt.Ltd. It/Ites Sez, Koba Gandhinagar – 382 421 Pan : Aaycs 8711 R (Applicant) (Responent) : Shri Hardik Vora, Ar Assessee By : Shri Atul Pandey, Sr.Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 13/08/2025 घोषणा क" तारीख /Date Of Pronouncement: 14/08/2025 आदेश/O R D E R Per Makarand V.Mahadeokar, Am:

For Appellant: Shri Atul Pandey, Sr.DR
Section 10ASection 115JSection 143(1)Section 143(1)(a)

learned CIT(A) held that there was no error in the CPC’s action in denying the deduction in processing under section 143(1) of the Act. The CIT(A) further observed that under section 119(2)(b) of the Singularity Labs Pvt.Ltd. vs. ITO Asst.Year ... facts of the present case the deduction under section 10AA of the Act can be denied at the stage of processing under section 143(1)(a) of the Act merely on account of a short procedural delay in e-filing Form 56F, notwithstanding the fact that (i) the claim

Society for Advancement of Villagers Empowerment and Rehabilitation for All, Kolkata vs. ITO (Exemp) Ward-2(2), New Delhi

The appeal of the assessee is allowed

ITA 2784/DEL/2023[2015-16]Status: DisposedITAT Delhi14 Aug 2025AY 2015-16

Bench: Ms. Madhumita Roy & Shri Naveen Chandrasociety For Advancement Of Vs. Ito (Exem), Ward 2(2) Villagers Empowerment, Pratyakshkar Bhawan C/O, M/S Salarpuria Spm Civic Centre, Jajodia & Co., 7, C.R. New Delhi - 110002 Avenue, 3Rd Floor, Kolkata, West Bengal – 700 072 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aacas3377F Appellant .. Respondent

For Appellant: Sh. Siddharth Jhajharia, CAFor Respondent: Sh. Manish Gupta, Sr. DR
Section 11Section 12ASection 12A(1)(b)Section 143(1)Section 143(1)(a)Section 154

along with the return of income filed on 12.01.2016 and the same was filed on 25.08.2018 i.e. after the intimation of the processing under Section 143(1) received by the assessee. 5. It is the case of the assessee that while rejecting the application for rectification the ITO (Exemption) ignored

Channagiri Arecanut Growers and Marketing Sowarda Co-Operative Association, Davangere vs. ITO, Ward-1, Davanagere

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

ITA 262/BANG/2025[2021-22]Status: DisposedITAT Bangalore06 Aug 2025AY 2021-22

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2021-22

For Appellant: Shri M Monish Sowkar, AdvocateFor Respondent: Shri Balusamy N, JCIT (DR)
Section 143(1)Section 80PSection 80P(2)(a)

parties and perused the records. We note that the deduction under section 80P(2)(a)(i) of the Act was denied during processing under section 143(1) of the Act. The ld. CIT(A) upheld . Page 3 of 4 the disallowance, stating that there was no evidence on record

Pushpa Bai Munat, Badnawar vs. CPC, Bangaluru

Appeal is allowed accordingly

ITA 125/IND/2025[2017-18]Status: DisposedITAT Indore31 Jul 2025AY 2017-18

Bench: Shri B.M. Biyani

Section 139Section 143(1)Section 203ASection 206CSection 80T

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

Kabiguru Path Bhaban, Kolkata vs. ITO, Exemption, Ward 1(4), Kolkata

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

ITA 1165/KOL/2025[2024-2025]Status: DisposedITAT Kolkata31 Jul 2025AY 2024-2025

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1165/Kol/2025 Assessment Year: 2024-25 Kobiguru Path Bhaban.………..……..…………………....Appellant 8B Tala, Bhabanath Sen Street, Shyambazar, Kol-4. [Pan: Aaetk0386P] Vs. Ito, Ward-1(4), Kolkata…………....…..………………….…..... Respondent Appearances By: Shri Manish Tiwari, Fca, Appeared On Behalf Of The Appellant. Shri Ranu Biswas, Acit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 30, 2025 Date Of Pronouncing The Order : July 31, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Dated 25.03.2025, For The Assessment Year 2024–25, Passed Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For A.Y. 2024–25 On 25.09.2024, Claiming Exemption Under Section 11 Of The Act. It Is Noted That The Audit Report Applicable In The Case Of The Assessee Was Form 10Bb, Which Was Filed On 26.12.2024. The Centralized Processing Centre (Cpc), Bengaluru, Processed The Return Under Section 143(1) Of The Act & Passed An Intimation Order Dated 28.01.2025, Disallowing Exemption Under Section 11, Citing That Form 10Bb Was Not Filed Within The Prescribed Time. Against This, The

Section 11Section 143(1)Section 154Section 250

remains no dispute, the appeal I.T.A. No.1165/Kol/2025 Kobiguru Path Bhaban becomes infructuous. Moreover, the audit report having been filed before completion of processing under Section 143(1), there was no delay or default on the part of the assessee. In view of the above, the impugned appellate order passed

Silk Association of India, Kolkata vs. ITO, Ward 8(2), Kolkata

In the result, the appeal of the assessee is allowed

ITA 705/KOL/2025[2023-24]Status: DisposedITAT Kolkata30 Jul 2025AY 2023-24

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.705/Kol/2025 Assessment Year: 2023-24 Silk Association Of India……...……..…………………....Appellant C/O P K Himmatsinghka & Co. 41, B B Ganguly Street, 2Nd Floor, Kol-12. [Pan: Aaocs9213J] Vs. Ito, Ward-8(2), Kolkata…………………..………………….…..... Respondent Appearances By: Shri P. K. Himmatsinghka, Ar, Appeared On Behalf Of The Appellant. Shri Kallol Mistry, Jcit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : July 29, 2025 Date Of Pronouncing The Order : July 30, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Dated 31.01.2025 Passed By The Cit, Appeal Addl/Jcit(A)-7, Mumbhai [In Short Cit(A)] Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Ate That The Assessee’S Accounts Were Duly Audited For The Financial Year Ending On 31.03.2023. The Audit Report In Form 10B Was Signed On 01.09.2023 & The Unique Document Identification Number (Udin) Was Generated On 20.10.2023. However, Due To Unforeseen Technical Glitches, The Assessee Was Unable To Upload Form 10B On The E-Filing Portal Within The Prescribed Due Date Of 31.10.2023. The Form Was Eventually Uploaded On 16.11.2023, Resulting In A Delay Of 16 Days. The Return Of Income Under Section 139 Read With Section 139(4A) Of The Act Was Filed On 18.11.2023, Which Was Within The Extended Due Date Of 30.11.2023. Additionally, Form 10

Section 11Section 11(2)Section 139Section 143(1)Section 250

filed on 17.10.2023, declaring accumulation of income amounting to ₹1,75,359. Despite these compliances, the return was processed under Section 143(1) of the Act by the CPC, disallowing exemption under Sections 11 and 12 on the sole ground that Form 10B was uploaded belatedly on 16.11.2023 instead ... audit report in Form 10B was admittedly signed and UDIN generated prior to the due date and before the completion of the processing under Section 143(1). The delay in uploading the same was due to a bona fide technical issue and cannot be a ground to deny exemption under

International Commission on Irrigation and Drainage Employees Provident Fund (Icid Pf Trust), New Delhi vs. Commissioner of Income Tax (Appeals), Delhi

In the result, both appeals of the assessee are allowed as above

ITA 4204/DEL/2024[2014-15]Status: DisposedITAT Delhi20 Jun 2025AY 2014-15

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishra

Section 10Section 10(21)Section 10(25)(ii)Section 11Section 12ASection 143(1)Section 154

Column 12 of part B of TI (Total Income)]. These ITRs were processed under section 143(1) of the Act wherein the AO (CPC) disallowed the claim of exemption under section 10 of the Act on the reasoning that the assessee was not eligible for said exemption under specified ... duly mentioned in ITRs. Later, the assessee filed applications under section 154 of the Act for rectification of the processing under section 143(1) of the Act for allowing exemption under section 10(25)(ii) of the Act. The said rectification applications were rejected on the reasoning that there

International Commission on Irrigation and Drainage Employees Provident Fund (Icid Pf Trust), New Delhi vs. Commissioner of Income Tax (Appeals), Delhi

In the result, both appeals of the assessee are allowed as above

ITA 4203/DEL/2024[2015-16]Status: DisposedITAT Delhi20 Jun 2025AY 2015-16

Bench: Shri Anubhav Sharma & Shri Avdhesh Kumar Mishra

Section 10Section 10(21)Section 10(25)(ii)Section 11Section 12ASection 143(1)Section 154

Column 12 of part B of TI (Total Income)]. These ITRs were processed under section 143(1) of the Act wherein the AO (CPC) disallowed the claim of exemption under section 10 of the Act on the reasoning that the assessee was not eligible for said exemption under specified ... duly mentioned in ITRs. Later, the assessee filed applications under section 154 of the Act for rectification of the processing under section 143(1) of the Act for allowing exemption under section 10(25)(ii) of the Act. The said rectification applications were rejected on the reasoning that there

Iit Investrust Limited, Mumbai vs. Income Tax Officer, 491)(2), Mumbai

ITA 3420/MUM/2024[2008-09]Status: DisposedITAT Mumbai09 Jun 2025AY 2008-09
For Respondent: Ms. Vranda Matkari
Section 143(1)Section 154Section 55(2)(ab)

present appeal. 4. In the present case the return of income filed by the Assessee for the Assessment Year 2008-2009 was processed under Section 143(1) of the Act and intimation dated, 26/11/2009, was issued. Subsequently, an application filed by the Assessee on 28/07/2010, a Rectification Order, dated 11/08/2010

Tarsem Chand Rana, Una vs. Jurisdictional Assessing Officer, ITO Ward 98, Una, Range Code 37

In the result, the appeal of the Assessee is dismissed

ITA 1085/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh02 Jun 2025AY 2020-21

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1085/Chd/2024 "नधा"रण वष" / Assessment Year : 2020-21 Tarsem Singh Rana, Ito, बनाम H.No. 4, Kathoh, Ward 98, Khurwain, Una Vs. Bangana H.P. 174321 "थायी लेखा सं./Pan No: Aawpr5715R अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Ajit Kumar Jha, Advocate (Virtual Mode) राज"व क" ओर से/ Revenue By : Dr. Ranjit Kaur, Addl. Cit, Sr.Dr

For Appellant: Sh. Ajit Kumar Jha, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr.DR
Section 143(1)Section 154Section 2(24)(x)Section 250Section 36(1)(va)

security agency, filed its income tax return for AY 2020-21 on 07.11.2020, declaring an income of Rs. 16,75,950/-. Upon processing under section 143(1) of the Income Tax Act, 1961, an intimation dated 22.12.2021 was issued, which was later rectified by order passed under section

Rajesh Kumar Jaiswal, Allahabad vs. Deputy/ACIT(Central), Allahabad

In the result, the appeal of the assessee is partly allowed

ITA 16/ALLD/2023[2018-19]Status: DisposedITAT Allahabad02 May 2025AY 2018-19

Bench: the query raised by the assessing authority vide questionnaire issued under section 142 (1) dated 23.01.2021, in assessment proceedings for the AY 2018-19.

For Appellant: Sh. Nikhil Agarwal & Ms. VidishaFor Respondent: Sh. A.K. Singh, Sr. DR
Section 115Section 115BSection 142Section 24Section 250Section 68Section 69

Crores. It was submitted that the assessee could not file the revised return because the return of the assessee had already been processed under section 143(1). However, it was submitted that the amount of Rs. 1.85 Crores would form a part of a declared income because it had been ... processing, because section 139(5) only restricts the filing of a revised return if an assessment has been completed and processing under section 143(1) was not an assessment. It was, therefore, submitted that the assessee could have paid the tax and revised the return if his bona fides

Mysore District Judicial Employee Credit Co-Operative Society Limited, Mysore vs. Income Tax Officer, Ward-1(1), Mysore

In the result, the appeal of the assessee is hereby allowed

ITA 1271/BANG/2024[2020-21]Status: DisposedITAT Bangalore21 Apr 2025AY 2020-21

Bench: Shri Waseem Ahmedassessment Year: 2020-21

For Appellant: Shri Pranav Krishna, AdvocateFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept
Section 139Section 139(1)Section 139(4)Section 140BSection 143(1)Section 80PSection 80P(2)Section 80P(2)(a)

contended that once the return has been held invalid, the same cannot be used for drawing any adverse inference against the after processing under section 143(1) of the Act. 10. On the other hand, the learned DR before me supported the order of the authorities below by making refence ... disallowance of the assessee’s claim for deduction under section 80P of the Act, amounting to ₹ 35,86,483/-, as processed under section 143(1) of the Act. The assessee is a cooperative society engaged in the business of providing credit facilities to its members. For the assessment year

DCIT/ACIT, Circle (Exemption), Nagpur vs. Sant Shankar Maharaj Aashram, Dhamangaon Amravati

In the result, Revenue’s appeal stands dismissed

ITA 573/NAG/2024[2018-19]Status: DisposedITAT Nagpur21 Mar 2025AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Sandipkumar Salunke
Section 143Section 144Section 270ASection 270A(2)Section 271

income. A person shall be considered to have under reported his income, if- 1. Income assessed is greater than income returned after processing under section 143(1). 2. Income assessed is greater than maximum amount not chargeable to tax, where no return of income has been furnished. 3. The income ... reassessed is greater than income assessed. 4. Deemed Tl u/s 115.JB or 115JC is greater than deemed TI after processing under section 143(1). 5. Deemed Tl u/s 115.JB or 115JC is greater than deemed TI is greater than maximum amount not chargeable to tax where no return has been

Income Tax Officer (Exemption) - 4, Nagpur vs. Deendayal Seva Pratishthan, Yavatmal

In the result, appeal by the Revenue stands dismissed

ITA 572/NAG/2024[2021-22]Status: DisposedITAT Nagpur21 Mar 2025AY 2021-22

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Kishore B. PhadkeFor Respondent: Shri Abhay Y. Marathe
Section 11Section 12Section 138

provisions under section 11 of the Act. The Central Processing Centre (CPC), Bengaluru, 4 Deendayal Seva Pratishthan ITA no.572/Nag./2024 carried out processing under section 143(1) of the Act of the return of the assessee trust on 19/10/2022 rejecting the claim of exemption under section

Sant Shankar Maharaj Aashram, Amravati vs. DCIT ACIT Cir-Exemp, Nagpur

In the result, Revenue’s appeal stands dismissed

ITA 504/NAG/2024[2018-19]Status: DisposedITAT Nagpur21 Mar 2025AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Sandipkumar Salunke
Section 143Section 144Section 270ASection 270A(2)Section 271

income. A person shall be considered to have under reported his income, if- 1. Income assessed is greater than income returned after processing under section 143(1). 2. Income assessed is greater than maximum amount not chargeable to tax, where no return of income has been furnished. 3. The income ... reassessed is greater than income assessed. 4. Deemed Tl u/s 115.JB or 115JC is greater than deemed TI after processing under section 143(1). 5. Deemed Tl u/s 115.JB or 115JC is greater than deemed TI is greater than maximum amount not chargeable to tax where no return has been

Sbw Udyog Limited, Prayagraj vs. DCIT, Cir-1, Allahabad

In the result, the appeal of the assessee is dismissed

ITA 27/ALLD/2024[2021-22]Status: DisposedITAT Allahabad13 Mar 2025AY 2021-22

Bench: Sh.Sudhanshu Srivastava & Sh. Nikhil Choudharya.Y.2021-22 Sbw Udyog Limited, Vs. Deputy Commissioner Of Income 44, Thornhill Road, Prayagraj Tax, Circle-1, Prayagraj Pan:Aadcs2883B (Appellant) (Respondent) Assessee By: Sh. N.C. Agrawal, C.A. Revenue By: Sh. A.K. Singh, Sr. Dr Date Of Hearing: 18.12.2024 Date Of Pronouncement: 13 .03.2025 O R D E R Per Nikhil Choudhary, A.M.: This Is An Appeal Filed Against The Orders Of The Ld. Cit(A) Under Section 250 Of The Income Tax Act, 1961 On 31.01.2024, Dismissing The Appeal Of The Assessee Against The Orders Of The Cpc Bengaluru, Under Section, 143(1) Dated 17.10.2022. Subsequently, The Said Appeal Was Migrated To The Nfac & Later On, The Appeal Proceedings Were Transferred To The Additional / Jcit(A), Aurangabad, Who Has Dismissed The Appeal Of The Assessee. The Grounds Of Appeal Preferred By The Assessee Are As Under:- “1. Because, Income Tax Department, Ministry Of Finance, Government Of India Has Observed In The Notice Under Section 250 Of The Income Tax Act, 1961, Which Reads As Under:- "The Income Tax Department Recognizes & Is Sensitive To The Hardships Being Faced By Taxpayers In Coping With The Challenges Posed By Covid-19 Pandemic." Consequently, Appeal Is Liable To Be Allowed.

For Appellant: Sh. N.C. Agrawal, C.AFor Respondent: Sh. A.K. Singh, Sr. DR
Section 143Section 250Section 36(1)(va)Section 43B

decision. The ld. AR further reiterated that because section 143(3) was an assessment it stood on a greater footing to a processing under section 143(1) and in a proceeding under section 143(3), the ld. AO had the power to review the processing done under section 143(1