“Section 143(1)(a)(i)”

Section References (mined)Section 143Section 143(1)(a)(i)104 judgments

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

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

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)(i)

Hemson Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 2(1)(1), Mumbai

In the result, all the appeals are allowed in the terms indicated above

ITA 1897/MUM/2022[2012-13]Status: DisposedITAT Mumbai10 Aug 2022AY 2012-13

Section 143(1)Section 36(1)(va)Section 44A

first appellate authority was not justified in upholding the adjustment, made by the Centralized Processing Centre Bengaluru while processing income tax returns under section 143(1) based on certain inputs from the tax audit reports of the assessee in question, in respect of the disallowance on account of delay ... total of such, as perceived by the tax auditor, delayed payments, aggregating to Rs 4,24,634 , were sought to be disallowed under section 143(1). When the assessee was put to notice, by the Dy. Commissioner of Income Tax, CPC, Bangalore (hereinafter referred to as 'the Assessing Officer

M/S. Logicon Alternate Fuels Pvt. Ltd, Mumbai vs. Dy.Commissioner of Income Tax, CPC, Bangalore

In the result, all the appeals are allowed in the terms indicated above

ITA 1842/MUM/2022[2018-19]Status: HeardITAT Mumbai10 Aug 2022AY 2018-19

Section 143(1)Section 36(1)(va)Section 44A

M/S Paper Recycle, Mumbai vs. CIT (Appeal), Delhi

In the result, appeal of the assessee is allowed

ITA 694/MUM/2022[2020-21]Status: DisposedITAT Mumbai26 Jul 2022AY 2020-21

Bench: The Due Date Of Filing Of Income Tax Returns U/S.139(1) Of The Act, Could Be Subject Matter Of Adjustment U/S.143(1)(A) Of The Act By The Central Processing Centre (Cpc).

Section 139(1)Section 143Section 143(1)Section 143(1)(a)Section 36(1)(va)Section 44A

learned CIT(A) was not justified in upholding the adjustment, made by the Centralized Processing Centre Bengaluru while processing income tax returns under section 143(1) based on certain inputs from the tax audit reports of the assessee in question, in respect of the disallowance ... total of such, as perceived by the tax auditor, delayed payments, aggregating to Rs 4,24,634 , were sought to be disallowed under section 143(1). When the assessee was put to notice, by the Dy. Commissioner of Income Tax, CPC, Bangalore (hereinafter referred to as 'the Assessing Officer

Aaryans Security Force, Mumbai vs. CIT (A) NFAC, Delhi

In the result, this appeal is allowed

ITA 1875/MUM/2021[2019-20]Status: DisposedITAT Mumbai15 Jul 2022AY 2019-20

Section 143Section 143(1)Section 143(1)(a)Section 154Section 36(1)(va)Section 44A

learned CIT(A) was not justified in upholding the adjustment, made by the Centralized Processing Centre Bengaluru while processing income tax returns under section 143(1) based on certain inputs from the tax audit reports of the assessee in question, in respect of the disallowance ... total of such, as perceived by the tax auditor, delayed payments, aggregating to Rs 4,24,634 ,were sought to be disallowed under section 143(1). When the assessee was put to notice, by the Dy Commissioner of Income Tax, CPC, Bangalore (hereinafter referred to as „the Assessing Officer

M/S. Oriental Trading Co., Mumbai vs. CIT (A) NFAC, Mumbai

In the result, both the appeals filed by the assessee are allowed

ITA 2329/MUM/2021[2018-19]Status: DisposedITAT Mumbai11 Jul 2022AY 2018-19

Bench: Shri Amit Shukla, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No. 2329 & 2330/Mum/2021 (निर्धारणवर्ा / Assessment Year: 2018-19 & 2019-20) Cit(A) - Nfac M/S Oriental Trading Co. Mumbai. 1St Floor, Elite House, Punjab बिधम/ Foundry, Near Classic Studio, Vs. Mira Road East, Mumbai-400 107 स्थायीलेखासं./जीआइआरसं./ Pan No. Aaafo7024L (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri Sanjay Parikh, Ld. Ar प्रत्यथीकीओरसे/Respondent By : Shri Nihar Ranjan Samal, Ld. Dr सुनवाईकीतारीख/ : 11.07.2022 Date Of Hearing घोषणाकीतारीख / : 11.07.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeals Have Been Filed By The Assessee Against The Separate Impugned Order Of Even Date 26.10.2021, Passed By National Faceless Appeal Centre (Nfac), Delhi, In Relation To Adjustment Made U/S 143(1) For The Ay 2018-19 & 2019-20. 2

For Appellant: Shri Sanjay Parikh, Ld. ARFor Respondent: Shri Nihar Ranjan Samal

Section 139Section 143(1)Section 143(1)(a)Section 36(1)(va)Section 43BSection 80

careful look at the related statutory provisions, that there is a material difference in the scheme of processing the income tax return under section 143(1)(a) as it stands now vis-à-vis as it stood at the point of time when Khatau Junkar judgment (supra ... only when such a deduction was “on the basis of information available in such return, accounts or documents is prima facie inadmissible” [see Section 143(1)(a)(iii) as it then stood] and it was in this context that the connotations of the expression “prima facie inadmissible” came

DCIT, Circle -1, Thane vs. M/S Accura Pharmaquip Pvt Ltd, Mumbai

In the result, the appeal filed by the revenue stands dismissed

ITA 969/MUM/2022[2018-19]Status: DisposedITAT Mumbai30 Jun 2022AY 2018-19

For Appellant: NoneFor Respondent: Dr. Pratap Narayan Sharma (Sr. AR)

Section 1Section 143(1)Section 143(1)(a)Section 154Section 36(1)(va)Section 43BSection 44A

total of such, as perceived by the tax auditor, delayed payments, aggregating to Rs 4,24,634 ,weresought to be disallowed under section 143(1). When the assesseewas put to notice, by the Dy Commissioner of Income Tax, CPC, Bangalore (hereinafter referred to as ‘the Assessing Officer- CPC’) in respect ... proposed adjustment under section 143(1) for this disallowance, the assessee objected to the adjustment so proposed.As evident from the uncontroverted facts set out in the Statement of Facts before the learned CIT(A), it was categoricallypointed out by the assessee, through an online communication to the Assessing Officer

Jagdamba Service Solution Pvt Ltd, Mumbai vs. CIT(A) (NFAC)- Delhi, Delhi

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

ITA 913/MUM/2022[2018-19]Status: DisposedITAT Mumbai30 Jun 2022AY 2018-19

For Appellant: NoneFor Respondent: Dr. Pratap Narayan Sharma (Sr. AR)

Section 143(1)Section 154Section 36(1)(va)Section 43BSection 44A

total of such, as perceived by the tax auditor, delayed payments, aggregating to Rs 4,24,634 ,weresought to be disallowed under section 143(1). When the assesseewas put to notice, by the Dy Commissioner of Income Tax, CPC, Bangalore (hereinafter referred to as ‘the Assessing Officer- CPC’) in respect ... proposed adjustment under section 143(1) for this disallowance, the assessee objected to the adjustment so 3 A.Y. 2018-19 Jagdamba Service Solution Pvt. Ltd. proposed.As evident from the uncontroverted facts set out in the Statement of Facts before the learned CIT(A), it was categoricallypointed out by the assessee

T K Steel Rolling Mills Private Limited, Mumbai vs. DCIT, CPC, Bangaluru

In the result, all the appeals are allowed in the terms indicated above

ITA 892/MUM/2022[2019-20]Status: DisposedITAT Mumbai30 Jun 2022AY 2019-20

first appellate authority was not justified in upholding the adjustment, made by the Centralized Processing Centre Bengaluru while processing income tax returns under section 143(1) based on certain inputs from the tax audit reports of the assessee in question, in respect of the disallowance on account of delay ... Ghatge Patil Transports Ltd [(2014) 368 ITR 749 (Bom)] and the limited scope or adjustments which can be made under section 143(1), he also fairly accepted that so far as this aspect of the matter is concerned, the issue is covered, in favour of the assessee, by a coordinate

T K Steel Rolling Mills Private Limited, Mumbai vs. DCIT, CPC, Bangaluru

In the result, all the appeals are allowed in the terms indicated above

ITA 891/MUM/2022[2018-19]Status: DisposedITAT Mumbai30 Jun 2022AY 2018-19

first appellate authority was not justified in upholding the adjustment, made by the Centralized Processing Centre Bengaluru while processing income tax returns under section 143(1) based on certain inputs from the tax audit reports of the assessee in question, in respect of the disallowance on account of delay ... Ghatge Patil Transports Ltd [(2014) 368 ITR 749 (Bom)] and the limited scope or adjustments which can be made under section 143(1), he also fairly accepted that so far as this aspect of the matter is concerned, the issue is covered, in favour of the assessee, by a coordinate

Surana Motors Private Limited, Mumbai vs. Dy CIT, CPC, Bangalore

In the result, all the appeals are allowed in the terms indicated above

ITA 846/MUM/2022[2018-19]Status: DisposedITAT Mumbai30 Jun 2022AY 2018-19

first appellate authority was not justified in upholding the adjustment, made by the Centralized Processing Centre Bengaluru while processing income tax returns under section 143(1) based on certain inputs from the tax audit reports of the assessee in question, in respect of the disallowance on account of delay ... Ghatge Patil Transports Ltd [(2014) 368 ITR 749 (Bom)] and the limited scope or adjustments which can be made under section 143(1), he also fairly accepted that so far as this aspect of the matter is concerned, the issue is covered, in favour of the assessee, by a coordinate

Master Polishers Private Limited, Mumbai vs. DCIT, CPC, Mumbai

In the result, all the appeals are allowed in the terms indicated above

ITA 845/MUM/2022[2017-18]Status: DisposedITAT Mumbai30 Jun 2022AY 2017-18

first appellate authority was not justified in upholding the adjustment, made by the Centralized Processing Centre Bengaluru while processing income tax returns under section 143(1) based on certain inputs from the tax audit reports of the assessee in question, in respect of the disallowance on account of delay ... Ghatge Patil Transports Ltd [(2014) 368 ITR 749 (Bom)] and the limited scope or adjustments which can be made under section 143(1), he also fairly accepted that so far as this aspect of the matter is concerned, the issue is covered, in favour of the assessee, by a coordinate

Nilesh V. Metha, Mumbai vs. DCIT 32(1), Mumbai

In the result, all the appeals are allowed in the terms indicated above

ITA 1150/MUM/2022[2019-20]Status: HeardITAT Mumbai30 Jun 2022AY 2019-20

first appellate authority was not justified in upholding the adjustment, made by the Centralized Processing Centre Bengaluru while processing income tax returns under section 143(1) based on certain inputs from the tax audit reports of the assessee in question, in respect of the disallowance on account of delay ... Ghatge Patil Transports Ltd [(2014) 368 ITR 749 (Bom)] and the limited scope or adjustments which can be made under section 143(1), he also fairly accepted that so far as this aspect of the matter is concerned, the issue is covered, in favour of the assessee, by a coordinate

M/S Vaishali Pharma Limited, Mumbai vs. Dy CIT CPC, Bangaluru

In the result, all the appeals are allowed in the terms indicated above

ITA 1122/MUM/2022[2017-18]Status: DisposedITAT Mumbai30 Jun 2022AY 2017-18

first appellate authority was not justified in upholding the adjustment, made by the Centralized Processing Centre Bengaluru while processing income tax returns under section 143(1) based on certain inputs from the tax audit reports of the assessee in question, in respect of the disallowance on account of delay ... Ghatge Patil Transports Ltd [(2014) 368 ITR 749 (Bom)] and the limited scope or adjustments which can be made under section 143(1), he also fairly accepted that so far as this aspect of the matter is concerned, the issue is covered, in favour of the assessee, by a coordinate

M/S. Mazgaon Dock Shipbuilders Ltd, Mumbai vs. Addl/Jt/Dy/ACIT, Delhi

In the result, the appeal of the assessee is allowed

ITA 1078/MUM/2022[2019-20]Status: DisposedITAT Mumbai30 Jun 2022AY 2019-20

For Appellant: NoneFor Respondent: Dr. Pratap Narayan Sharma (Sr. AR)

Section 143(1)Section 36(1)(va)Section 43BSection 44A

Stg Refractory Services Pvt. Ltd., Mumbai-400042 vs. Dy Commissioner of Income Tax, Central Processing Centre, Karnataka-560500

In the result, all the appeals are allowed in the terms indicated above

ITA 1063/MUM/2022[2018-19]Status: DisposedITAT Mumbai30 Jun 2022AY 2018-19

first appellate authority was not justified in upholding the adjustment, made by the Centralized Processing Centre Bengaluru while processing income tax returns under section 143(1) based on certain inputs from the tax audit reports of the assessee in question, in respect of the disallowance on account of delay ... Ghatge Patil Transports Ltd [(2014) 368 ITR 749 (Bom)] and the limited scope or adjustments which can be made under section 143(1), he also fairly accepted that so far as this aspect of the matter is concerned, the issue is covered, in favour of the assessee, by a coordinate

Chauhan Lifters, Mumbai vs. Commissioner of Income Tax (A) NFAC, Delhi

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

ITA 1289/MUM/2022[2019-20]Status: DisposedITAT Mumbai29 Jun 2022AY 2019-20

Bench: Shri Amit Shukla, Jm & Shri Gagan Goyal, Am आयकरअपीलसं./ I.T.A. No. 1289/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2019-20) National Faceless Chauhan Lifters Appeal Centre (Nfac), 124-3, Bhaskar Niwas Road No. बिधम/ Delhi 4, Scheme No. 6, Sion East, Vs. Maharashtra-400 022 स्थायीलेखासं./जीआइआरसं./ Pan No. Aakfc2375E (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By None : प्रत्यथीकीओरसे/Respondent By : Shri Mahita Nayar, Ld. Dr सुनवाईकीतारीख/ : 29.06.2022 Date Of Hearing घोषणाकीतारीख / : 29.06.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 26.10.2021, Passed By National Faceless Appeal Centre (Nfac), Delhi, In Relation To Adjustment Made U/S 143(1) For The Ay 2019-20. 2

For Respondent: Shri Mahita Nayar, Ld. DR

Section 139Section 139(1)Section 143(1)Section 143(1)(a)Section 36(1)(va)Section 43BSection 80

M/S S. K. International, Mumbai vs. DCIT 17(1), Mumbai

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

ITA 1251/MUM/2022[2019-20]Status: DisposedITAT Mumbai29 Jun 2022AY 2019-20

Bench: Shri Amit Shukla, Jm & Shri Gagan Goyal, Am आयकरअपीलसं./ I.T.A. No. 1251/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2019-20) Dcit-17(1), M/S. S. K. International Kautilya Bhavan, Near S. K. House, 94-A, Aval Baug, बिधम/ Videsh Bhavan, Bandra D. S. P. Road, Dadar (E), Vs. Kurla, Mumbai-400 051 Mumbai-400 014 स्थायीलेखासं./जीआइआरसं./ Pan No. Aamfs2232C (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By None : प्रत्यथीकीओरसे/Respondent By : Shri Mahita Nayar, Ld. Dr सुनवाईकीतारीख/ : 29.06.2022 Date Of Hearing घोषणाकीतारीख / : 29.06.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 22.04.2022, Passed By National Faceless Appeal Centre (Nfac), Delhi, In Relation To Adjustment Made U/S 143(1) For The Ay 2019-20. 2

For Respondent: Shri Mahita Nayar, Ld. DR

Section 139Section 139(1)Section 143(1)Section 143(1)(a)Section 36(1)(va)Section 43BSection 80

Agaskar Civil & Garden Contractors, Mumbai vs. NFAC, Delhi

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

ITA 1247/MUM/2022[2019-20]Status: DisposedITAT Mumbai29 Jun 2022AY 2019-20

Bench: Shri Amit Shukla, Jm & Shri Gagan Goyal, Am आयकरअपीलसं./ I.T.A. No. 1247/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2019-20) National Faceless Agaskar Civil & Garden Appeal Centre (Nfac), Contractors बिधम/ Delhi Plot No. A-249, Namdeo Smruti, Vs. Sector-19, Koparkhairanine, Navi Mumbai-400 709 स्थायीलेखासं./जीआइआरसं./ Pan No. Abcfa6438K (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : None प्रत्यथीकीओरसे/Respondent By : Shri Mahita Nayar, Ld. Dr सुनवाईकीतारीख/ : 29.06.2022 Date Of Hearing घोषणाकीतारीख / : 29.06.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 30.03.2022, Passed By National Faceless Appeal Centre (Nfac), Delhi, In Relation To Adjustment Made U/S 143(1) For The Ay 2019-20. 2

For Appellant: NoneFor Respondent: Shri Mahita Nayar, Ld. DR

Section 139Section 139(1)Section 143(1)Section 143(1)(a)Section 36(1)(va)Section 43BSection 80

Pace Setters Business Solutions Pvt. Ltd, Mumbai vs. Dy.CIT CPC Bangalore & Cir 8(2) (1), Mumbai

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

ITA 1216/MUM/2022[2018-19]Status: DisposedITAT Mumbai29 Jun 2022AY 2018-19

Bench: Shri Amit Shukla, Jm & Shri Gagan Goyal, Am आयकरअपीलसं./ I.T.A. No. 1216/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2018-19) Dcit, Cpc, Bangalore & Pace Setters Business Circle 8(2)(1), Mumbai Solutions Pvt. Ltd. बिधम/ 1 Bori Bunglow, 49 S K Bole Vs. Road, Prabhadevi, Mumbai-400 028 स्थायीलेखासं./जीआइआरसं./ Pan No. Aadcp7717M (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : Shri Bharat Kumar, Ld. Ar अपीलाथीकीओरसे/ Appellant By : प्रत्यथीकीओरसे/Respondent By : Shri Mahita Nayar, Ld. Dr सुनवाईकीतारीख/ : 29.06.2022 Date Of Hearing घोषणाकीतारीख / : 29.06.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 23.03.2022, Passed By National Faceless Appeal Centre (Nfac), Delhi, In Relation To Adjustment Made U/S 143(1) For The Ay 2018-19. 2

For Respondent: Shri Mahita Nayar, Ld. DR

Section 139Section 139(1)Section 143(1)Section 143(1)(a)Section 36(1)(va)Section 43BSection 80

Seven S Banking Management Consultancy Services (P) Ltd, Mumbai-400069 vs. Circle-11(2)(1), Mumbai-400020

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

ITA 1167/MUM/2022[2019-20]Status: DisposedITAT Mumbai29 Jun 2022AY 2019-20

Bench: Shri Amit Shukla, Jm & Shri Gagan Goyal, Am आयकरअपीलसं./ I.T.A. No. 1167/Mum/2022 (निर्धारणवर्ा / Assessment Year: 2019-20) Circle-11(2)(1), Seven S Banking Management Mumbai Consultancy Services (P) Ltd. बिधम/ Office No. 104, Eco Heights, Shree Nityanand Society, Vs. Swami Nityanand Marg, Andheri East, Mumbai-400 069 स्थायीलेखासं./जीआइआरसं./ Pan No. Aaecs7701B (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : None प्रत्यथीकीओरसे/Respondent By : Shri Mahita Nayar, Ld. Dr सुनवाईकीतारीख/ : 29.06.2022 Date Of Hearing घोषणाकीतारीख / : 29.06.2022 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: The Aforesaid Appeal Has Been Filed By The Assessee Against The Impugned Order Dated 26.03.2022, Passed By National Faceless Appeal Centre (Nfac), Delhi, In Relation To Adjustment Made U/S 143(1) For The Ay 2019-20. 2

For Appellant: NoneFor Respondent: Shri Mahita Nayar, Ld. DR

Section 139Section 139(1)Section 143(1)Section 143(1)(a)Section 36(1)(va)Section 43BSection 80