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“Section 143(3)”

Section References (mined)Section 143Section 143(3)45,044 judgments

The decision most relied on for Section 143(3) is National Thermal Power Co. Ltd. v. CIT (229 ITR 383), cited in 5,834 judgments on BharatTax.

Leading authorities on Section 143(3)

National Thermal Power Co. Ltd. v. CIT
229 ITR 383 · 1998 · Supreme Court
5,834
citing judgments

Appellate authorities can consider new claims and additional grounds if the relevant facts are already on record. The purpose of assessment is to correctly determine tax liability, allowing both parties to raise issues.

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. Vegetable Products Ltd.
88 ITR 192 · 1973 · Supreme Court
2,664
citing judgments

When two equally plausible interpretations of a taxing provision are possible, or when conflicting views exist from non-jurisdictional High Courts, the interpretation that favors the assessee must be adopted.

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.

Pr. CIT v. Abhisar Buildwell (P.) Ltd.
149 Taxmann.com 399 · 2023 · Supreme Court
2,379
citing judgments

An assessment under section 153A is without jurisdiction if there is an absence of incriminating material for an unabated assessment year.

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.

Judgments citing Section 143(3)

Tonmoy Sadhukhan, Bhangar vs. ITO, Ward 25(1), Kolkata

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 2291/KOL/2025[2017-2018]Status: DisposedITAT Kolkata08 Jan 2026AY 2017-2018

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2017-18 Tonmoy Sadhukhan…………..……..………………….……….……….……Appellant Ghatakpukur, Gobindapur Bhangar, South 24 Parganas 743502, Wb – 743502. [Pan: Cbzps8992R] Vs. Ito, Ward-25(1), Kolkata…………………………..…….....……...…..…..Respondent Appearances By: Shri P. K. Rai, Adv, H. Mukhopadhaya & Trideep Nayak, Adv., Appeared On Behalf Of The Appellant. Shri Pradip Kr. Biswas, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 11, 2025 Date Of Pronouncing The Order : January 08, 2026 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 12.02.2024 Of The Nfac, Delhi (Hereinafter Referred To As The “Cit(A)”) Passed U/S 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2017–18. 2. The Appeal Has Been Filed By The Assessee With A Delay Of 528 Days. The Assessee Has Filed An Affidavit For Condonation Of The Delay, Which Is Self-Explanatory. After Going Over The Said Affidavit, We Find That The Delay Was Occurred Due To Unusual Circumstances Which Was Beyond The Control Of The Assessee & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 143(2)Section 143(3)Section 250Section 69A

आयकर अपील"य अ"धकरण, कोलकाता पीठ, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH KOLKATA Before Shri Rajesh

Shriram Finance Ltd., Chennai vs. PCIT, Chennai

ITA 2043/CHNY/2025[2022-23]Status: DisposedITAT Chennai08 Jan 2026AY 2022-23

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2043/Chny/2025 िनधा"रण वष"/Assessment Year: 2022-23 Shriram Finance Limited, Vs. The Principal Commissioner Of [Since Shriram City Union Finance Income Tax – 3, Limited Amalgamated With Shriram Chennai. Transport Finance Co. Limited & Presently Known As Shriram Finance Limited], Sri Towers, Plot No. 14A, South Phase, Industrial Estate, Guindy, Chennai 600 032. [Pan:Aaacs7018R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri C.N. Bipin, Cit सुनवाई की तारीख/ Date Of Hearing : 15.10.2025 घोषणा की तारीख /Date Of Pronouncement : 08.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.05.2025 Passed By The Ld. Principal Commissioner Of Income Tax – 3, Chennai For The Assessment Year 2022-23 Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Shri C.N. Bipin, CIT
Section 143(3)Section 234DSection 263Section 36(1)(vii)Section 36(1)(viia)Section 4

subsequently filed revised return on 31.12.2022 declaring total income of ₹.1548,25,12,670/-. The case was selected for scrutiny and assessment under section 143(3) r.w.s. 144B of the Act was completed on 29.02.2024 by assessing the income of the assessee at ₹.1549,48,21,820/- after making ... PCIT passed the impugned order under section 263 of the Act treating the assessment order dated 29.02.2024 passed by the Assessing Officer under section 143(3) of the Act as erroneous and prejudicial to the interest of the Revenue, is not justified. He vehemently argued that the fact of amalgamation

Manoj Kumar Verma, Meerut vs. National Faceless Appeal Centre (NFAC), Delhi

Appeal is partly allowed

ITA 4212/DEL/2024[2017-18]Status: DisposedITAT Delhi08 Jan 2026AY 2017-18

Bench: Shri Satbeer Singh Godara & Shri S Rifaur Rahmanassessment Year: 2017-18 Sh. Manoj Kumar Verma, Vs. Nfac, Prop. Md Jewellers, 1103/2, Delhi Shastri Nagar, Meerut Pan: Aazpv9933A (Appellant) (Respondent) Assessee By None Department By Ms. Ankush Kalra, Sr. Dr Date Of Hearing 08.01.2026 Date Of Pronouncement 08.01.2026 Order Per Satbeer Singh Godara, Jm This Assessee’S Appeal For Assessment Year 2017-18, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The “Cit(A)/Nfac”], Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1067013650(1), Dated 25.07.2024 Involving Proceedings Under Section 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Case Called Twice. None Appears At The Assessee’S Behest. He Is Accordingly Proceeded Ex-Parte. 2. Learned Departmental Representative Vehemently Argues That Both The Learned Lower Authorities Have Rightly Treated The Assessee’S Cash Deposits & Unsecured Loans Of Rs.92 Lakhs & Rs.17 Lakhs; Respectively, Under Section 69A & Section 68 Of The Act; In Assessment Order Dated 18.11.2019 As Upheld In The Lower Appellate Discussion. 3. We Have Given Our Thoughtful Consideration To The Assesseee’S & The Revenue’S Respective Pleadings. The Revenue Could Hardly Dispute That Even Going By The Assessing Officer’S Assessment Discussion, The Assessee Had Admitted Total Sales In Jewellery Wholesale & Retail Business Activity, As The Case May Be, Amounting To Rs.8.69 Crores, Rs.9.16 Crores & Rs.14.99 Crores For F.Y. 2015-16, 2016-17 & 2017-18, Respectively. Necessary Inference Which Would Prima Facie Arise In The Assessee’S Favour In This Backdrop Is That The Impugned Cash Deposits Form Part Of His Jewellery Sales Only; Although Not Reconciled & Verified To The Entire Satisfaction Of Both The Learned Lower Authorities.

Section 115BSection 143(3)Section 68Section 69A

/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2024-25/1067013650(1), dated 25.07.2024 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Case called twice. None appears at the assessee’s behest