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“Section 143(1)(a)(v)”

Section References (mined)Section 143Section 143(1)(a)(v)183 judgments

The decision most relied on for Section 143(1)(a)(v) is Collector, Land Acquisition v. Mst. Katiji (167 ITR 471), cited in 3,926 judgments on BharatTax.

Leading authorities on Section 143(1)(a)(v)

Collector, Land Acquisition v. Mst. Katiji
167 ITR 471 · 1987 · Supreme Court
3,926
citing judgments

Delay in filing appeals, when supported by sufficient or justifiable cause, should be condoned with a liberal approach to ensure substantial justice. This principle prioritizes the cause of justice over mere technicalities.

CIT v. Kabul Chawla
380 ITR 573 · 2016 · High Court
3,235
citing judgments

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

Malabar Industrial Co. Ltd. v. CIT
243 ITR 83 · 2000 · Supreme Court
2,943
citing judgments

For revision under Section 263, the Assessing Officer's order must be both erroneous and prejudicial to the interests of the revenue; if either condition is not met, the revisionary jurisdiction cannot be invoked. An order is not erroneous merely because the Assessing Officer did not record the details of enquiries conducted, provided due enquiries were made.

CIT v. Manjunatha Cotton & Ginning Factory
359 ITR 565 · 2013 · High Court
2,590
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

CIT v. Multiplan India Ltd.
38 ITD 320 · 1991 · ITAT
2,267
citing judgments

An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

CIT v. Reliance Petroproducts Pvt. Ltd.
322 ITR 158 · 2010 · Supreme Court
2,228
citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

CIT v. Reliance Utilities & Power Ltd.
313 ITR 340 · 2009 · High Court
2,118
citing judgments

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such investments.

Estate of Late Tukojirao Holkar v. CWT
223 ITR 480 · 1997 · High Court
2,040
citing judgments

A court or tribunal is not bound to answer a reference or adjudicate an appeal on its merits if the party at whose instance the proceeding is made fails to appear at the hearing or take necessary steps for its proper conduct.

Judgments citing Section 143(1)(a)(v)

Dagadudhondu Yeola Nagari Sahakari Patsanstha Maryadit, Satana vs. The Income Tax Officer, Ward 1(1), Nashik

In the result, the appeal of the assessee is allowed as per the terms indicated hereinabove

ITA 2326/PUN/2025[2018-19]Status: DisposedITAT Pune12 Feb 2026AY 2018-19

Bench: Dr.Manish Boradआयकर अपील सं. / Ita No.2326/Pun/2025 Assessment Year : 2018-19 Dagadudhondu Yeola Nagari Vs. Income Tax Officer, Sahakari Patsanstha Maryadit, Ward-1(1), Nashik At Post Satana, Nashik 423 301 Maharashtra Pan : Aabad2549P Appellant Respondent

For Appellant: Shri Sanjeev MuthaFor Respondent: Shri Eknath Abhang
Section 10ASection 139Section 139(1)Section 143(1)(a)Section 154Section 250Section 80P

find that the said powers have been conferred to the CPC by the Finance Act, 2021 w.e.f. 01.04.2021 in section 143(1)(a)(v) of the Act subsequent to which the CPC is empowered to make prima-facie adjustment to disallow the claim of deduction u/s.10AA or deduction claimed under

Sri Sowrabha Mahila Pattina Sahakara Sangha, Tumkur vs. Income Tax Officer, Ward-1, Tiptur

The appeals are dismissed, however

ITA 117/BANG/2025[2019-20]Status: DisposedITAT Bangalore09 Feb 2026AY 2019-20

Bench: Shri Prashant Maharishi, Vice – & Shri Soundararajan K.Assessment Year : 2019-20

For Appellant: Ms. Sahana T.H.M, Advocate
Section 119(2)(b)Section 143(1)Section 143(1)(a)Section 80ASection 80P

return of income is filed beyond the due date prescribed under Section 139(1), when the existence of a specific clause, Section 143(1)(a)(v), which was amended with effect from April 1, 2021, to address such disallowances exists, but can be denied by CPC holding ... disallowance of such a claim during ) automated processing under Section Page 9 of 20 143(1) would specifically fall under Section 143(1)(a)(v), a provision introduced to address this issue. c.) Further, sixth proviso to Section 139(1), inserted by the Finance Act, 2021, specifies that

Fdcm Karmachari Sahaka, Chandrapur vs. ITO Ward-2, Chandrapur

In the result, appeal of the Assessee is allowed

ITA 313/NAG/2025[2018-19]Status: DisposedITAT Nagpur03 Feb 2026AY 2018-19

Bench: Dr. Manish Borad

For Appellant: Shri Mohammed Lakkadsha, CAFor Respondent: Shri Surjit Kumar Saha, Sr.DR
Section 143(1)(a)Section 250Section 80ASection 80PSection 80P(2)(a)

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR “SMC” BENCH : NAGPUR (Through virtual) BEFORE DR. MANISH BORAD, ACCOUNTANT MEMBER I.T.A.No.313/NAG/2025

Fule Shahu Ambedkar Z P Karmachari Sah Pat Sanstha, Washim vs. Income Tax Officer Ward-2, Akola

In the result, appeal of the Assessee is allowed

ITA 68/NAG/2024[2019-20]Status: DisposedITAT Nagpur03 Feb 2026AY 2019-20

Bench: Dr. Manish Borad

For Appellant: NoneFor Respondent: Shri Surjit Kumar Saha, Sr.DR
Section 143(1)(a)Section 250Section 80ASection 80P

IN THE INCOME TAX APPELLATE TRIBUNAL NAGPUR “SMC” BENCH : NAGPUR (Through virtual) BEFORE DR. MANISH BORAD, ACCOUNTANT MEMBER I.T.A.No.68/NAG/2024

Mahaveer Nagari Sahakari Patpedhi Limited, Amalner vs. ITO Ward 1(4) Jalgaon, Jalgaon

In the result, appeal of the assessee is allowed

ITA 2228/PUN/2025[2016-17]Status: DisposedITAT Pune30 Jan 2026AY 2016-17

Bench: SHRI VINAY BHAMORE (Judicial Member)

Section 139Section 139(1)Section 143(1)(a)Section 144BSection 147Section 148Section 148ASection 250Section 80PSection 80P(2)(a)

Valid ITR u/s 139(1) of the Act, hence, the deduction is not allowable to the appellant. As per the provision of section 143(1)(a)(v) of the Act, no deduction under chapter VIA is allowable if the return of income is furnished beyond the due date specified under ... brought on record any contrary decision of the Hon’ble Jurisdictional High Court. 9. Ld.CIT(A) has confirmed the decision relying on Section 143(1)(a)(v) of the Act. In this case, order u/s.143(3) r.w.s 147 of 9 ITA Nos.2227 & 2228/PUN/2025 [A] the Act, was passed. Also

Mahaveer Nagari Sahakari Patpedhi Limited, Amalner vs. ITO Ward 1(4) Jalgaon, Jalgaon

In the result, appeal of the assessee is allowed

ITA 2227/PUN/2025[2015-16]Status: DisposedITAT Pune30 Jan 2026AY 2015-16
Section 139Section 139(1)Section 143(1)(a)Section 144BSection 147Section 148Section 148ASection 250Section 80PSection 80P(2)(a)

Valid ITR u/s 139(1) of the Act, hence, the deduction is not allowable to the appellant. As per the provision of section 143(1)(a)(v) of the Act, no deduction under chapter VIA is allowable if the return of income is furnished beyond the due date specified under ... brought on record any contrary decision of the Hon’ble Jurisdictional High Court. 9. Ld.CIT(A) has confirmed the decision relying on Section 143(1)(a)(v) of the Act. In this case, order u/s.143(3) r.w.s 147 of 9 ITA Nos.2227 & 2228/PUN/2025 [A] the Act, was passed. Also

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

ITA 7122/MUM/2025[2014-15]Status: DisposedITAT Mumbai08 Jan 2026AY 2014-15

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

For Appellant: Shri Vijay Shah, ARFor Respondent: Assessee by
Section 139(1)Section 143(1)Section 143(1)(a)Section 154Section 80ASection 80A(5)Section 80PSection 80P(2)(d)

vide order dated 28.06.2024, wherein the ITAT has held that the disallowance of deduction under Chapter-VIA can be made under section 143(1)(a)(v) of the Act, only on account of non-furnishing of return of income within the due date of filing of the return

Shree Jalaram Coop. Credit Society Ltd, Viramgam vs. The ITO, Ward-3(2)(1), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1951/AHD/2025[2019-20]Status: DisposedITAT Ahmedabad06 Jan 2026AY 2019-20

Bench: Ms. Suchitra Kambleassessment Year 2019-20

For Appellant: Shri S.N. DivetiaFor Respondent: Shri Suresh Chand Meena, Sr. D.R
Section 139(1)Section 143(1)Section 143(1)(a)Section 154Section 250Section 80PSection 80P(2)(a)

THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “SMC” BENCH Before Ms. Suchitra Kamble, Judicial Member Assessment Year 2019-20 Shree Jalram

Kedambadi Milk Producers Co-Operative Women Society Limited, Kedambadi vs. Income Tax Officer Ward 1 Puttur, Puttur

In the result appeal of the assessee is dismissed

ITA 280/BANG/2025[2019-2020]Status: DisposedITAT Bangalore22 Dec 2025AY 2019-2020

Bench: Shri Prashant Maharishiassessment Year : 2019-20

For Appellant: Shri Krishna Kantila, CAFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing Counsel
Section 139Section 139(1)Section 143Section 154Section 80Section 80ASection 80PSection 80p

return of income is filed beyond the due date prescribed under Section 139(1), when the existence of a specific clause, Section 143(1)(a)(v), which was amended with effect from April 1, 2021, to address such disallowances exists, but can be denied by CPC holding ... disallowance of such a claim during automated processing under Section 143(1) would specifically fall Page 6 of 14 under Section 143(1)(a)(v), a provision introduced to address this issue. c) Further , sixth proviso to Section 139(1), inserted by the Finance Act, 2021, specifies that

Chikkamudnoor Milk Producers Co-Operative Society Limited, Chikkamudnoor vs. Income Tax Officer, Ward-1, Puttur

In the result appeal of the assessee is dismissed

ITA 104/BANG/2025[2019-20]Status: DisposedITAT Bangalore22 Dec 2025AY 2019-20

Bench: Shri Prashant Maharishiassessment Year : 2019-20

For Appellant: Shri Krishna Kantila, CAFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing Counsel
Section 139Section 139(1)Section 143Section 154Section 80Section 80ASection 80PSection 80p

return of income is filed beyond the due date prescribed under Section 139(1), when the existence of a specific clause, Section 143(1)(a)(v), which was amended with effect from April 1, 2021, to address such disallowances exists, but can be denied by CPC holding ... disallowance of such a claim during automated processing under Section 143(1) would specifically fall Page 6 of 14 under Section 143(1)(a)(v), a provision introduced to address this issue. c) Further , sixth proviso to Section 139(1), inserted by the Finance Act, 2021, specifies that

Vidyut Transmission Karmachari Vetan Bhogi Credit Cooperative Society, Lucknow vs. CPC Bangalore/ITO-2(1), Lucknow

Appeal of the assessee is partly allowed for statistical

ITA 464/LKW/2025[2019-20]Status: DisposedITAT Lucknow19 Dec 2025AY 2019-20

Bench: Shri Kul Bharat & Shri Anadee Nath Misshra

Section 139(1)Section 139(4)Section 143(1)Section 143(1)(a)Section 80PSection 80P(2)(a)

section 80P of the Act falls under provisions of Chapter VIA of the Act. It is a fact that the amendment to Section 143(1)(a)(v) of the Act, enabling disallowance of deduction claimed Chapter VIA of the Act, was made by the Finance Act, 2021, w.e.f ... noted that denial of claim under section 80P would not come within purview of prima facie adjustment under section 143(1)(a)(v) for reason that said section was not in force during period under consideration i.e. assessment year 2019-20 Further case of assessee would also not fall within

Chunakhali Samabay Krishi Unnayan Samity Ltd., Berhampore, Murshidabad vs. I.T.O., Ward - 56(3), Murshidabad

In the result, the appeal of the assessee is allowed

ITA 943/KOL/2025[2020-2021]Status: DisposedITAT Kolkata08 Dec 2025AY 2020-2021

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(1)Section 143(1)(a)Section 250Section 80Section 80ASection 80P

deduction u/s. 80P of the Act solely for the reason that return was not filed within the due date. Provisions of section 143(1)(a)(v) provides that - “(v) disallowance of deduction claimed under section 10AA or under any of the provisions of Chapter VIA under the heading “C - Deductions

DCIT, Swargate Pune vs. Cummins India Ltd, Pune

In the result, appeal of the assessee bearing ITA No

ITA 1256/PUN/2023[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Ms. Astha Chandra

Section 10ASection 115JSection 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 35

claim treating the same to be incorrect claim u/s.143(1)(a)(ii) of the Act and also invoking the provisions of section 143(1)(a)(v) of the Act. We further notice that the said claim has been denied not on the ground of non-fulfillment of relevant conditions prescribed ... treating the same to be an "Incorrect Claim under section 143(1)(a)(ii) of the Act" and also invoking provisions of "section 143(1)(a)(v) of the Act. I agree with the appellant's contention that erroneous information provided in Sr. No.12 in Schedule Part

Cummins India Limited, Pune vs. Assistant Commissioner of Income-Tax, Circle - 1(1), Pune

In the result, appeal of the assessee bearing ITA No

ITA 632/PUN/2022[2018-19]Status: DisposedITAT Pune04 Dec 2025AY 2018-19

Bench: Dr.Manish Borad & Ms. Astha Chandra

For Appellant: Shri J.D. Mistri, Sr. Advocate &For Respondent: Shri Prakash L. Pathade, CIT-DR
Section 10ASection 13Section 143(1)Section 143(1)(a)Section 143(2)Section 143(3)Section 144C(5)Section 14ASection 250Section 80J

claim treating the same to be incorrect claim u/s. 143(1)(a)(ii) of the Act and also invoking the provisions of section 143(1)(a)(v) of the Act. We further notice that the said claim has been denied not on the ground of non-fulfillment of relevant conditions ... treating the same to be an "Incorrect Claim under section 143(1)(a)(ii) of the Act" and also invoking provisions of "section 143(1)(a)(v) of the Act. I agree with the appellant's contention that erroneous information provided in Sr. No.12 in Schedule Part

Nabarun S K U S Ltd., Nadia vs. I.T.O.Ward-41(1), Krishnanagar

ITA 89/KOL/2025[2018-19]Status: DisposedITAT Kolkata01 Dec 2025AY 2018-19
Section 119Section 139Section 80Section 80ASection 80P

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, KOLKATA SHRI PRADIP KUMAR CHOUBEY, JUDICIAL MEMBER SHRI SANJAY AWASTHI, ACCOUNTANT MEMBER

Satgramr. Colliery Employees Cooperative Credit Society Limited, Asansol vs. Assistant Commissioner of Income Tax, Circle-1, Asansol

In the result, the appeal of the assessee is allowed

ITA 1920/KOL/2025[2019-2020]Status: DisposedITAT Kolkata25 Nov 2025AY 2019-2020

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.1920/Kol/2025 Assessment Year: 2019-20 Satgram R Collery Employees Cooperative Credit Society Ltd……....Appellant Satgram Project, P.O Debichand Nagar, Block-Jamuria-1, Asansol, W.B. 713332. [Pan: Aajas8427K] Vs. Acit, Circle-1, Asansol……..……………....…..………………….…..... Respondent Appearances By: Shri Abhijit Banerjee, Advocate, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborty, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : November 24, 2025 Date Of Pronouncing The Order : November 25, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre (Hereinafter Referred To As “Ld. Cit(A)”) Dated 03.02.2025 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. At The Time Of Hearing Of The Matter, The Learned Representative Submitted That There Was A Delay Of 115 Days In Filing The Appeal. In This Connection, The Assessee Filed An Affidavit Explaining The Reasons For The Delay. After Considering The Submissions Of The Assessee & Examining The Contents Of The Affidavit, We Are Satisfied That The Reasons For The Delay Are Bona Fide & Deserve To Be Condoned.

Section 139(1)Section 143(1)Section 143(1)(a)Section 250Section 80P

appeal before the Tribunal. The assessee contends that the intimation under section 143(1) dated 29.09.2020 was passed before the amendment to section 143(1)(a)(v) of the Act came into effect on 01.04.2021. Prior to 01.04.2021, CPC did not possess the power to disallow claims under Chapter ... enabling provision permitting disallowance of deductions under Chapter VI-A for delayed filing of the return was inserted in section 143(1)(a)(v) of the Act with effect from 01.04.2021. Thus, on the date when the assessee’s return was processed, the statutory power to make such an adjustment

Nagahat Tea Estate Private Limited, Kolkata vs. Income Tax Officer Ward -1, Jorhat

ITA 20/GTY/2025[2022-23]Status: DisposedITAT Guwahati17 Nov 2025AY 2022-23

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 119(1)Section 119(2)(b)Section 139(1)Section 139(9)Section 143(1)Section 143(1)(a)Section 250Section 36(1)Section 36(1)(va)Section 80

various judgement of the Apex Court/ High Court/ ITAT. 6. That white processing the impugned intimation u/s 143(1)(a)} section 143(1)(a)(v) of the Act specifically provides that the deduction u/s 80-1E of the Act can be disallowed only if the return of income

Nagahat Tea Estate Private Limited, Kolkata vs. Income Tax Officer Ward -1, Jorhat

ITA 19/GTY/2025[2021-22]Status: DisposedITAT Guwahati17 Nov 2025AY 2021-22

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 119(1)Section 119(2)(b)Section 139(1)Section 139(9)Section 143(1)Section 143(1)(a)Section 250Section 36(1)Section 36(1)(va)Section 80

various judgement of the Apex Court/ High Court/ ITAT. 6. That white processing the impugned intimation u/s 143(1)(a)} section 143(1)(a)(v) of the Act specifically provides that the deduction u/s 80-1E of the Act can be disallowed only if the return of income

Nagahat Tea Estate Private Limited, Kolkata vs. Income Tax Officer Ward -1, Jorhat

ITA 18/GTY/2025[2020-21]Status: DisposedITAT Guwahati17 Nov 2025AY 2020-21

Bench: SHRI MANOMOHAN DAS, JUDICIAL MEMBER SHRI SANJAY AWASTHI (Accountant Member)

Section 119(1)Section 119(2)(b)Section 139(1)Section 139(9)Section 143(1)Section 143(1)(a)Section 250Section 36(1)Section 36(1)(va)Section 80

various judgement of the Apex Court/ High Court/ ITAT. 6. That white processing the impugned intimation u/s 143(1)(a)} section 143(1)(a)(v) of the Act specifically provides that the deduction u/s 80-1E of the Act can be disallowed only if the return of income

Shree Chalala VI Ka Seva Sahakari Mandali Ltd., Amreli vs. The ITO Ward 3(1)(4), Rajkot-Amreli., Rajkot

The appeal of the assessee is allowed

ITA 358/RJT/2025[2019-20]Status: DisposedITAT Rajkot17 Nov 2025AY 2019-20

Bench: Dr. Arjun Lal Saini, A Ccountant Member & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 358/Rjt/2025 िनधा"रण वष" / Assessment Year: (2019-20) Shree Chalala Vi Ka Seva Sahakari Vs. The Ito Ward 3(1)(4), Mandali Ltd. Aayakar Bhavan, Race Course Ring Chalala Haveli Road, Road, Dhari Amreli - 365630 Rajkot - 360001 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Aatas2273D (Appellant) (Respondent) Appellant By : Ms. Devina Patel, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav Ld. Sr. Dr Date Of Hearing : 27/08/2025 Date Of Pronouncement : 17/11/2025 आदेश / O R D E R Per, Dinesh Mohan Sinha, Jm; Captioned Appeal Filed By Assessee Pertaining To Assessment Year 2019-20, Is Directed Against Order Passed Under Section 250 Of The Income Tax Act, 1961 By National Faceless Appeal Centre (Nfac), Delhi/Commissioner Of Income Tax (Appeals), Dated 31/03/2025, Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S 143(1) Of The Act. 2. The Grounds Of Appeal Raised By The Assessee Are As Follows: - 1. The Learned Addl/Jcit (A)-1, Kolkata Erred In Confirming Action Of Cpc, Bangalore In Disallowing Claim Of Deduction Of Rs. 3,51,828/- U/S Sop Of The Act By Failing To Appreciate That Provisions Of Sec. 143(1)(A)(V) Do Not Provide For Denial Of Deduction U/S 80P Of The Act When The Return Of Income Is Not Filed Within Time Allowed U/S 139(1) Of The Act But U/S 139(4). 2. The Learned Addl/Jcit (A)-1, Kolkata Erred In Upholding Action Of The Cpc, Bangalore In Making Adjustment To The Returned Income Of The Appellant By Way Of Shree Chalala Vikas Seva Sahkari Mandli Ltd.

For Appellant: Ms. Devina Patel, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav Ld. SR. DR
Section 119(2)(b)Section 139(1)Section 139(4)Section 143(1)Section 143(1)(a)Section 250Section 80PSection 80P(2)(d)

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, A CCOUNTANT MEMBER & SHRI DINESH MOHAN