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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)

Om Yash Projects Limited, Ahmedabad vs. The ITO, Ward-3(1)(1), Ahmedabad

The appeal of the assessee is allowed for statistical purposes

ITA 40/AHD/2025[2023-24]Status: DisposedITAT Ahmedabad12 Mar 2025AY 2023-24

Bench: Shri Siddhartha Nautiyal & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.40/Ahd/2025 िनधा"रण वष" /Assessment Year: 2023-24 Om Yash Projects Ltd., Income Tax Officer, Office No. 1113, Aaron Spectra, बनाम/ Ward-3(1)(1), V/S. Rajpath Rangoli Road, Bodakdev, Ahmedabad Ahmedabad-380054 "थायी लेखा सं./Pan: Aacco4734C अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Kaushik Kejriwal & Ms. Kushboo Shah, C.A. Revenue By : Shri Rignesh Das, Sr. Dr सुनवाई की तारीख/Date Of Hearing : 10/03/2025 घोषणा की तारीख /Date Of Pronouncement: 12/03/2025 आदेश/O R D E R Per Makarand V. Mahadeokar, Am: This Appeal Has Been Preferred By The Assessee Against The Order Passed By The Learned Additional / Joint From The Office Of The Commissioner Of Income Tax (Appeals)-2, Guwahati [Hereinafter Referred To As "Cit(A)"] Under Section 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As "The Act"], Dated 26.11.2024, In Connection With The Intimation Under Section 143(1) For The Assessment Year (A.Y.) 2023-24, Issued By The Centralized Processing Center (Cpc), Bangalore, Dated 09.01.2024. Om Yash Projects Ltd. Vs. Ito Asst. Year : 2023-24

For Appellant: Shri Kaushik Kejriwal & MsFor Respondent: Shri Rignesh Das, Sr. DR
Section 143(1)Section 143(3)Section 250

verification of TDS credit requires detailed examination, which falls within the scope of scrutiny assessment under section 143(3) rather than summary processing under section 143(1). The CIT(A) also failed to appreciate this jurisdictional issue and did not independently verify whether the amounts reflected in Form 26AS were

Shree Ambika Gramin Bigarsheti Sahakari Patsanstha Maryadit, Pune vs. ITO Ward 10(1), Pune

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

ITA 1329/PUN/2024[2021-22]Status: DisposedITAT Pune04 Mar 2025AY 2021-22

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1329/Pun/2024 िनधा"रण वष" / Assessment Year: 2021-22 Shree Ambika Gramin V The Income Tax Officer, Bigarsheti Sahakri Patsanstha S Ward-10(1), Pune. Maryadit, Khodad, Junnar, Pune – 410504. Pan: Aadas2545Q Appellant/ Assessee Respondent / Revenue Assessee By Shri Kishor B Phadke – Ar Revenue By Shri Ramnath P Murkunde – Dr Date Of Hearing 19/02/2025 Date Of Pronouncement 04/03/2025 आदेश/ Order Per Dr. Manish Borad, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] For Assessment Year 2021-22 Dated 08.03.2024 Passed U/Sec.250 Of The Income Tax Act, 1961. 1.1 Registry Informed That There Is A Delay 35 Days. We Have Carefully Gone Through The Affidavit & Notice That On Account Of

Section 143(1)Section 143(1)(A)Section 143(1)(a)Section 250Section 80P(2)(d)

time. 4.1 However, considering the facts and circumstances of the case and also the discrepancy observed by us. in the CPC processing under section 143(1)(a) of the Act, discussed(supra), we deem it appropriate to restore the issue raised by the assessee on merits of the case regarding

Devender Kumar Prashar, Delhi vs. Asst. Director of Income Tax, CPC, Bangaluru

In the result, the appeal of the assessee is allowed

ITA 176/GTY/2024[2019-20]Status: DisposedITAT Guwahati25 Feb 2025AY 2019-20

Bench: The Ld. Cit(A) Also, The Assessee Could Not Succeed On The Basis Of The Following Findings:

Section 143(1)Section 143(1)(a)Section 250

1) of the Act. To this extent, any adjustment under Section 50C of the Act is not possible at the stage of processing under Section 143(1) of the Act even if we analyse the situation from a different angle. We would see that while the Income Tax Department

United Church, Visakhapatnam vs. Income Tax Officer, Exemption Ward, Visakhapatnam

ITA 70/VIZ/2024[2021-22]Status: DisposedITAT Visakhapatnam13 Feb 2025AY 2021-22

Bench: Shri Laliet Kumar, Hon'Ble & Shri S Balakrishnan, Hon'Bleआयकर अपीलसं./I.T.A.Nos. 69 & 70/Viz/2024 (निर्धारणवर्ष/ Assessment Years: 2020-21 & 2021-22) United Church 60-8-3, Prakash Nagar Malkapuram Visakhapatnam – 530011 Andhra Pradesh [Pan: Aaatu6130B] (अपीलार्थी/ Appellant) V. Income Tax Officer Exemption Ward, Visakhapatnam Andhra Pradesh (प्रत्यर्थी/ Respondent) करदाता का प्रतिनिधित्व/ Assessee Represented By : Shri C. Subrahmanyam, Ar राजस्व का प्रतिनिधित्व/ Department Represented By : Shri N. Gopi Krishna, Sr.Ar सुनवाई समाप्त होने की तिथि/ Date Of Conclusion Of Hearing : 16.01.2025 घोषणा की तारीख/Date Of Pronouncement : 13.02.2025 आदेश /Order Per Shri S Balakrishnan: 1. These Appeals Are Filed By The Assessee Against Different Orders Learned Commissioner Of Income Tax/Addl/Jcit(A)-10, Mumbai [Hereinafter In Short "Ld.Cit(A)" Vide Respective Din &Orderno. As Stated Below: -

Section 11Section 12ASection 143(1)

filing of return of income was 15.02.2021 whereas assessee filed return of income after the due date. The return was summarily processed under section 143(1) of the Act on 01.06.2022 determining total income at Rs. 77,99,420/- after disallowance of the claim of exemption under section

Ehsaas, Gwalior vs. CIT (Appeals), NFAC (Delhi)

Appeal is allowed

ITA 5/AGR/2023[2015-16]Status: DisposedITAT Agra12 Feb 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manoj Kumar Aggarwal

For Respondent: Sh. Shailender Shrivastava, Sr. DR
Section 11Section 139(1)Section 143(1)Section 154

## IN THE INCOME TAX APPELLATE TRIBUNAL "SMC" BENCH, AGRA ## BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER & SHRI MANOJ KUMAR AGGARWAL

Sssp Consultant and Techno Services Private Limited, Mumbai vs. ACIT, Mumbai

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

ITA 719/MUM/2024[2015-16]Status: DisposedITAT Mumbai12 Feb 2025AY 2015-16

Bench: Shri Saktijit Dey & Shri B.R. Baskaran

For Appellant: Shri Naresh JainFor Respondent: Ms. Monika H. Pande
Section 133ASection 147Section 148

believe that income chargeable to tax has escaped Assessment. This basic condition precedent is applicable whether the return of income was processed under Section 143(1) of the Act by intimation or assessed byscrutiny under Section 143(3) of the Act. [See Asst. Commissioner ofIncome Tax v/s. Rajesh Jhaveri Stock ... Revenue. 7 Thus, we are of the view that even in cases where the return of income has been accepted by processing under Section 143(1) of the Act, reopening of an assessment can only be done when the Assessing Officer has reason to believe that income chargeable

Sssp Consultant and Techno Services Private Limited, Mumbai vs. ACIT, Mumbai

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

ITA 717/MUM/2024[2014-15]Status: DisposedITAT Mumbai12 Feb 2025AY 2014-15

Bench: Shri Saktijit Dey & Shri B.R. Baskaran

For Appellant: Shri Naresh JainFor Respondent: Ms. Monika H. Pande
Section 133ASection 147Section 148

believe that income chargeable to tax has escaped Assessment. This basic condition precedent is applicable whether the return of income was processed under Section 143(1) of the Act by intimation or assessed byscrutiny under Section 143(3) of the Act. [See Asst. Commissioner ofIncome Tax v/s. Rajesh Jhaveri Stock ... Revenue. 7 Thus, we are of the view that even in cases where the return of income has been accepted by processing under Section 143(1) of the Act, reopening of an assessment can only be done when the Assessing Officer has reason to believe that income chargeable

Shree Sree Balananda Trust, Deoghar vs. ITO, Exemption Ward, Dhanbad

In the result, this appeal of assessee is allowed

ITA 16/RAN/2023[2016-17]Status: DisposedITAT Ranchi04 Feb 2025AY 2016-17

Bench: Shri Partha Sarathi Chaudhuryshree Sree Balananda Trust, I.T.O., Sri Sri Balananda Ashram, Karinabad, Exemption Ward, Vs. Deoghar, Dist.- Deoghar, Dhanbad. Jharkhand-841112 Pan No. Aabts 0579 H Appellant/ Assessee Respondent/ Revenue

Section 11Section 13(9)Section 139(1)Section 143(1)Section 143(1)(a)Section 143(2)Section 154

status of a firm to 'association of persons' which needs physical verification and it cannot be mechanically done vide intimation and processing under Section 143(1)(a) of the Act. The same view had been upheld by the coordinate Kolkata Bench in ITA No. 1187 & 1188/Kol/2018

The Sangeet Plaza Iftex Office Premises Coop Soc Limited, Mumbai vs. Income Tax Officer, Mumbai

In the result, the appeal is hereby allowed

ITA 5541/MUM/2024[2021-22]Status: DisposedITAT Mumbai30 Dec 2024AY 2021-22

Bench: Shri Anikesh Banerjee

For Respondent: Shri Asif Karmali (Sr. DR)
Section 143(1)Section 143(3)Section 154Section 80PSection 80P(2)Section 80P(2)(d)

IN THE INCOME-TAX APPELLATE TRIBUNAL “J(SMC)” BENCH, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT

Deputy Commissioner of Income Tax, Central Circle-2, Ludhaina vs. Homeland City Project Ltd, New Delhi

In the result, the appeal of the Revenue is dismissed

ITA 559/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh17 Dec 2024AY 2020-21

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rohit Sharma, CIT DR
Section 143(1)Section 143(1)(a)Section 37

adjudicated on merits, gone beyond the audit report and admitted other material- an exercise impermissible under the inherently limited scope of processing under section 143(1)(a)? 3 Whether on the facts and in the circumstances of the case, the learned CIT(A) has taken a stand vitiated

Prukalpa Sankar, Bangalore vs. Income Tax Officer, Ward 5(3)(5), Bengaluru

Appeal of the assessee is allowed for statistical purposes

ITA 2100/BANG/2024[2019-20]Status: DisposedITAT Bangalore16 Dec 2024AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Karanjot Singh K & Devashish JainFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept
Section 139(1)Section 143(1)Section 143(1)(a)Section 143(3)Section 154Section 90

assessee being debatable. If the same reasoning is adopted, then such an adjustment can also not be made in the return processed under section 143(1) of the Act. 8.2 The second controversy, whether filing of form 67 is mandatory or directory, has been settled by the Bangalore ITAT ... income. However, we note that the quantum of FTC claimed by the assessee requires verification, which was not conducted during the processing under Section 143(1) of the Act. Accordingly, the matter needs to be remanded to the AO for verification. Considering the above, we direct the AO to verify

Prukalpa Sankar, Bangalore vs. Income Tax Officer, Ward 5(3)(5), Bengaluru

Appeal of the assessee is allowed for statistical purposes

ITA 2099/BANG/2024[2018-19]Status: DisposedITAT Bangalore16 Dec 2024AY 2018-19

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

For Appellant: Shri Karanjot Singh K & Devashish JainFor Respondent: Shri Ganesh R Gale, Standing Counsel for Dept
Section 139(1)Section 143(1)Section 143(1)(a)Section 143(3)Section 154Section 90

assessee being debatable. If the same reasoning is adopted, then such an adjustment can also not be made in the return processed under section 143(1) of the Act. 8.2 The second controversy, whether filing of form 67 is mandatory or directory, has been settled by the Bangalore ITAT ... income. However, we note that the quantum of FTC claimed by the assessee requires verification, which was not conducted during the processing under Section 143(1) of the Act. Accordingly, the matter needs to be remanded to the AO for verification. Considering the above, we direct the AO to verify

Kalidoss Natarajan, Bangalore vs. Deputy Commissioner of Income Tax, Circle-3(3)(1), Bangalore

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

ITA 1976/BANG/2024[2019-20]Status: DisposedITAT Bangalore28 Nov 2024AY 2019-20

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20

For Appellant: Shri Balaji V, C.AFor Respondent: Shri V Parithivel, JCIT (DR)
Section 139(1)Section 143(1)

denied if it is claimed in a revised return of income, which was available for consideration by the AO during the processing under Section 143(1) of the Act. In support of this contention, the AR relied on various judicial precedents. 7. On the other hand, the learned Departmental Representative

Abbott Healthcare Private Limited, Mumbai vs. Assistant Commissioner of Income Tax, Circle 2(1)(1), Mumbai

In the result, Ground No. 3 with its Sub-Grounds is allowed for statistical purposes

ITA 2756/MUM/2024[2019-20]Status: DisposedITAT Mumbai23 Sept 2024AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Gagan Goyalabbott Healthcare Pvt. Ltd. 3, Corporate Park, Sion Trombay Road, Mumbai - 400 071 Pan: Aaack3935D ..... Appellant Vs. Acit 2(1) (1) R. No. 561, 5Th Floor, Aayakar Bhavan, Maharishi Karve Marg, Mumbai- 400 020 ..... Respondent & Acit 2(1) (1) R. No. 561, 5Th Floor, Aayakar Bhavan, Maharishi Karve Marg, Mumbai- 400 020 ...... Appellant Vs.

For Appellant: Shri Madhur Agrawal, Ld. ARFor Respondent: Shri Manoj Kumar Sinha, Ld. DR
Section 143(1)Section 250Section 43B

indicates a disallowance in the tax Abbott Healthcare Pvt. Ltd. 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

M/S Nova Iron and Steel Ltd., Chandigarh vs. DCIT, CC-1, Chandigarh

Appeal of the assessee is partly allowed

ITA 303/CHANDI/2023[2020-21]Status: DisposedITAT Chandigarh30 Aug 2024AY 2020-21

Bench: Filing Of Income Tax Return.

For Appellant: Shri Ashwani Kumar, CA and Ms. Deepali Aggarwal, C.AFor Respondent: Smt. Kusum Bansal, CIT DR
Section 139(5)Section 143(1)Section 143(1)(a)Section 250Section 253Section 36(1)(va)Section 43B

return of income for A.Y. 2020-21 on 13/02/2021 declaring loss of Rs. 33,41,53,728/-. The return of income was processed under section 143(1) of the Act vide intimation dt. 25/11/2021. 2.1 The Centralised Processing Centre (CPC) Bengaluru while processing the return under section 143(1) unjustifiably ... contended that claim of depreciation of Rs. 1,03,13,420/- was wrongly allowed by the CPC, Bangaluru while processing under section 143(1) whereas the correct figure was Rs. 89,96,72,937/-. An application for rectification was made under section 154 but same came to be rejected

Silverline Cooperative Housing Society Ltd, Mumbai vs. Income Tax Officer, Ward-31(2)(1)

The appeal of the assessee is allowed and AO is directed to allow the claim

ITA 2601/MUM/2024[2014-15]Status: DisposedITAT Mumbai29 Aug 2024AY 2014-15

Bench: Shri Sandeep Singh Karhail & Smt. Renu Jauhri

For Appellant: Shri Rajesh ShahFor Respondent: Shri R. R. Makwana
Section 143(1)Section 154Section 250Section 80PSection 80P(2)Section 80P(2)(d)

IN THE INCOME-TAX APPELLATE TRIBUNAL “SMC” BENCH, MUMBAI BEFORE SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER & SMT. RENU JAUHRI, ACCOUNTANT

Jv of Tata Projects Limited and Chint Electric Company Limited, Noida vs. Income Tax Officer Ward 5(1)(3), Noida, Noida Uttar Pradesh

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

ITA 1140/DEL/2024[2019-20]Status: DisposedITAT Delhi14 Aug 2024AY 2019-20

Bench: BEFORESHRI KUL BHARAT (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

Section 143(1)Section 167BSection 167B(2)Section 167B(2)(ii)Section 234ASection 234BSection 234C

filed its Income Tax Return (In short, the ‘ITR’) on 31.10.2019 declaring income of Rs. 3,87,56,280/-. The ITR was processed under section 143(1) of the Act,wherein the Assessing Officer (CPC-ITR) [In short, the ‘AO’) applied tax rate of 40% on entire taxable income ... contended that the appellant/assessee had never been taxed @ 40% in the preceding and subsequent years. The Ld. AR with the help of processing under section 143(1) of the Act for AY 2018-19 2020-21 to 2023-24 demonstrated that the AO had applied the tax rate

Jawahar Lal Nehru Senior Secondary School, Gohana vs. ITO, Ward - 1, Sonipat

Accordingly, the grounds of appeal raised by the appellant are dismissed

ITA 2050/DEL/2024[2015-16]Status: DisposedITAT Delhi08 Aug 2024AY 2015-16

Bench: Ms. Madhumita Roy & Shri Avdhesh Kumar Mishra

Section 10Section 11Section 12ASection 143(1)Section 56Section 57

trust under section 12AA of the 3 Act has been treated as a valid ITR and that is why the same was processed under section 143(1) of the Act. Here in this case, instead of taxing income imbedded in the gross receipts, the entire receipts have been taxed ... income. Keeping in view the facts in entirety, we are of the considered opinion that the disallowance of entire expenses in processing under section 143(1) of the Act is not only against the accounting principle but also against the provisions of the Act. The impugned order of the JCIT

Shree Krishna Foundation, Mumbai vs. Income Tax Officer Exm Ward 2(3), Mumbai

In the result, an appeal bearing ITA No

ITA 2455/MUM/2024[2017-18]Status: DisposedITAT Mumbai29 Jul 2024AY 2017-18

Bench: Shriamarjit Singh & Shri Anikesh Banerjee

For Appellant: Ms. Rutuja N. PawarFor Respondent: ShriP.D. Choughule (All.CIT) SR DR
Section 12ASection 139(1)Section 143(1)Section 154Section 250

appellant isnot maintainable as no adjustment has been made r.w.s. the grounds of appeal taken in this appeal at the time of processing under section 143(1). In view of these facts and circumstances of the case and legal position, the present appeal is dismissed.” 7. On perusal

M/S. Checkmate Services Pvt. Ltd., Vadodara vs. The ADIT, CPC, Bangalore Present Juridiction the Dy. CIT, Circle-1(1)(1), Vadodara

In the result, appeal preferred by the assessee is dismissed

ITA 69/AHD/2023[2019-20]Status: DisposedITAT Ahmedabad16 Jul 2024AY 2019-20

Bench: Ms. Suchitra Raghunath Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 69/Ahd/2023 (िनधा"रण वष" िनधा"रण वष" / Assessment Year : 2019-20) िनधा"रण वष" िनधा"रण वष" M/S. Checkmate Adit, Cpc, बनाम बनाम/ बनाम बनाम Services Pvt. Ltd. Bangalore Vs. G.F 6-9, Amaan Tower & Suvas Colony, Fatehgunj, Dy.Cit Vadodara, Gujarat, Circle-1(1)(1), Vadodara 390002 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacc8465A (Appellant) .. (Respondent) Shri M. R. Sahu, Ar अपीलाथ" ओर से /Appellant By : ""यथ" क" ओर से/Respondent By : Dr. Darsi Suman Ratnam, Cit. Dr 12/07/2024 Date Of Hearing Date Of Pronouncement 16/07/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: This Appeal Is Filed By The Assessee Against The Order Of The National Faceless Appeal Centre (Nfac), Delhi, (In Short ‘The Cit(A)’) Dated 08.12.2022 For The Assessment Year 2019-20. 2. The Brief Facts Of The Case Are That Assessee Had Filed Its Return Of Income For A.Y. 2019-20 On 30.09.2019 Declaring Total

For Respondent: Dr. Darsi Suman Ratnam, CIT. DR
Section 143(1)Section 143(1)(a)

which is applicable to all proceedings whether it is scrutiny assessment under Section 143(3) of the Act or the proceeding of processing under Section 143(1) of the Act. The ratio decidendi laid down by the Hon’ble Apex Court holds the field and is binding in respect