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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)

Shri Jinnappanna Chougule Lalbahadur Credit Souhard Sahakari Sangh Niyamit, 2471, Lalbahadur Akkamahadevi Chowk, Shirguppi Ath vs. Income Tax Officer, Belgaum

In the result, the three appeals filed by the assessee are partly allowed for statistical purposes

ITA 275/PAN/2025[2017-18]Status: DisposedITAT Panaji07 Jan 2026AY 2017-18

Bench: Shri Pavan Kumar Gadalei T A. Nos.274,275 & 276/Pan/2025 (A.Y. 2015-16,2017-18 & 2018-19 ) Shri Jinnappanna Chougule Vs I T O, Lalbahadur Credit Souhard National E Assessment . Sahakari Niyamit, Centre, 2471,Lalbahadur Delhi. Akkamahadevi Chowk, Shirguppi Athani, Belagavi-591242, Karnataka. Pan .No. Aagas8466F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P(2)(a)

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH PANAJI BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER I T A. Nos.274

Shri Jinnappanna Chougule Lalbahadur Credit Souhard Sahakari Sangh Niyamit, Belgaum vs. Income Tax Officer, Belgaum

In the result, the three appeals filed by the assessee are partly allowed for statistical purposes

ITA 274/PAN/2025[2015-16]Status: DisposedITAT Panaji07 Jan 2026AY 2015-16

Bench: Shri Pavan Kumar Gadalei T A. Nos.274,275 & 276/Pan/2025 (A.Y. 2015-16,2017-18 & 2018-19 ) Shri Jinnappanna Chougule Vs I T O, Lalbahadur Credit Souhard National E Assessment . Sahakari Niyamit, Centre, 2471,Lalbahadur Delhi. Akkamahadevi Chowk, Shirguppi Athani, Belagavi-591242, Karnataka. Pan .No. Aagas8466F (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 80P(2)(a)

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH PANAJI BEFORE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER I T A. Nos.274

Saluja Steel and Power Pvt. Ltd., Giridih vs. ACIT, C, Dhanbad

In the result, appeal of the assessee is allowed

ITA 287/RAN/2025[13-14]Status: DisposedITAT Ranchi07 Jan 2026

Bench: SHRI GEORGE MATHAN (Judicial Member), SHRI RATNESH NANDAN SAHAY (Accountant Member)

For Appellant: Shri Devesh Poddar, AdvocateFor Respondent: Shri Rajib Jain, CIT-DR
Section 131Section 142(1)Section 143(3)Section 148Section 156

आयकर अपीलीय अधिकरण, र ाँची न्य यपीठ, र ाँची IN THE INCOME TAX APPELLATE TRIBUNAL RANCHI BENCH, RANCHI BEFORE SHRI

Colen Chemical Pvt. Ltd., Jamshedpur vs. ITO, Ward 1(1), Jamshedpur

In the result, both appeals of the assessee are allowed

ITA 167/RAN/2025[2014-15]Status: DisposedITAT Ranchi07 Jan 2026AY 2014-15

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita No.165 & 167/Ran/2025 (निि ारण वर्ा / Assessment Year :2013-2014 & 2014-2015) Colen Chemical Pvt. Ltd, Vs. Ito Ward-1(1), Jamshedpur 1St Floor, Room No.9, Tiwary Bechar Complex, Main Rd. Bistupur, Jamshedpur-831001 स्थायी लेखा सं./Pan No. : Aabcc 3978 K (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri Sunil Surana, Ar राजस्व की ओर से /Revenue By : Shri Ram Chandra Marndi, Sr.Dr सुनवाई की तारीख / Date Of Hearing : 07/01/2026 घोषणा की तारीख/Date Of Pronouncement : 07/01/2026 आदेश / O R D E R Per Bench : These Two Appeals Are Filed By The Assessee Against The Separate Orders Passed By The Ld.Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Both Dated 31.03.2025 For The Assessment Year 2013-2014. 2. It Was Submitted By The Ld.Ar That For The Assessment Year 2013- 2014 The Original Assessment Came To Be Completed U/S.143(3) Of The Act On 29/01/2016 & For The Assessment Year 2014-2015 The Original Assessment Came To Be Completed U/S.143(3) Of The Act On 29.12.2016. Notice U/S.148 Of The Act For A.Y.2013-2014 Came To Be Issued On 28.03.2018 & For A.Y.2014-2015 The Notice Was Issued On 24.06.2019. The Ld. Ar Drew Our Attention To Reason Recorded To Reopening For The Assessment Year 2013-2014 At Pages 47 To 51 Of The Paper Book Which Reads As Follows:-

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Ram Chandra Marndi, Sr.DR
Section 143(3)Section 147Section 148

आयकर अपीलीय अधिकरण, र ाँची न्य यपीठ, र ाँची IN THE INCOME TAX APPELLATE TRIBUNAL RANCHI BENCH, RANCHI BEFORE SHRI

Colen Chemical Pvt. Ltd., Jamshedpur vs. ITO, Ward 1(1), Jamshedpur

In the result, both appeals of the assessee are allowed

ITA 165/RAN/2025[2013-14]Status: DisposedITAT Ranchi07 Jan 2026AY 2013-14

Bench: Shri George Mathan, Jm & Shri Ratnesh Nandan Sahay, Am आयकर अपील सं./Ita No.165 & 167/Ran/2025 (निि ारण वर्ा / Assessment Year :2013-2014 & 2014-2015) Colen Chemical Pvt. Ltd, Vs. Ito Ward-1(1), Jamshedpur 1St Floor, Room No.9, Tiwary Bechar Complex, Main Rd. Bistupur, Jamshedpur-831001 स्थायी लेखा सं./Pan No. : Aabcc 3978 K (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) निर्ाारिती की ओर से /Assessee By : Shri Sunil Surana, Ar राजस्व की ओर से /Revenue By : Shri Ram Chandra Marndi, Sr.Dr सुनवाई की तारीख / Date Of Hearing : 07/01/2026 घोषणा की तारीख/Date Of Pronouncement : 07/01/2026 आदेश / O R D E R Per Bench : These Two Appeals Are Filed By The Assessee Against The Separate Orders Passed By The Ld.Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Both Dated 31.03.2025 For The Assessment Year 2013-2014. 2. It Was Submitted By The Ld.Ar That For The Assessment Year 2013- 2014 The Original Assessment Came To Be Completed U/S.143(3) Of The Act On 29/01/2016 & For The Assessment Year 2014-2015 The Original Assessment Came To Be Completed U/S.143(3) Of The Act On 29.12.2016. Notice U/S.148 Of The Act For A.Y.2013-2014 Came To Be Issued On 28.03.2018 & For A.Y.2014-2015 The Notice Was Issued On 24.06.2019. The Ld. Ar Drew Our Attention To Reason Recorded To Reopening For The Assessment Year 2013-2014 At Pages 47 To 51 Of The Paper Book Which Reads As Follows:-

For Appellant: Shri Sunil Surana, ARFor Respondent: Shri Ram Chandra Marndi, Sr.DR
Section 143(3)Section 147Section 148

आयकर अपीलीय अधिकरण, र ाँची न्य यपीठ, र ाँची IN THE INCOME TAX APPELLATE TRIBUNAL RANCHI BENCH, RANCHI BEFORE SHRI

Nityanand, Sant Kabir Nagar vs. Income Tax Officer, Basti

In the result, the appeal of the Assessee stands allowed for statistical purposes

ITA 470/LKW/2025[2016-17]Status: DisposedITAT Lucknow07 Jan 2026AY 2016-17

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2016-17 Nityanand V. The Income Tax Officer Vill. & Post Dhamaicha Basti Sant Kabir Nagar (U.P) Tan/Pan:Agzpn3158R (Applicant) (Respondent) Applicant By: Shri Vikram Acharya, Aca Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 06.03.2025, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2016-17. 2.0 The Brief Facts Of The Case Are That The Assessee Was A Teacher Employed With The Government Of U.P. & Earned Salary Income. The Assessee Had Not Filed The Return Of Income For The Year Under Consideration. The Income Tax Department Was In Possession Of Information That The Assessee Had Made Cash Deposits To The Tune Of Rs.2,16,55,000/- In His Bank Account No.144200101001330 Maintained With Corporation Bank During The Year Under Consideration & The Cash Deposited By The Assessee During The Demonetization Period, I.E. From 01.04.2015 To 31.302.016 Was Rs.15,05,000/-. The Assessing Officer (Ao)

For Respondent: Shri R.R.N. Shukla, D.R
Section 115BSection 142(1)Section 143(3)Section 144Section 147Section 148Section 69A

same was to be treated as unexplained money of the assessee under section 69A of the Act. The AO completed the assessment under section 143(3) read with 147 and 144B of the Act, assessing the total income of the assessee at Rs.18,06,870/-, after making an addition

Late Madan Lal Gupta Through Legal Heir Abhishek Gupta, Barabanki vs. ITO Ward 5(4), Barabanki-1, Barabanki

In the result, the appeal of the assessee stands allowed

ITA 437/LKW/2025[2017-18]Status: DisposedITAT Lucknow07 Jan 2026AY 2017-18

Bench: Shri. Sudhanshu Srivastavaassessment Year: 2017-18 Late Madan Lal Gupta V. Ito Through Legal Heir Ward 5(4) Abhishek Gupta Barabanki - 1 367, Qanoon Goyan Nawabganj, Barabanki U.P) Tan/Pan:Acepg5468Q (Applicant) (Respondent) Applicant By: Shri Gaurav Gupta, C.A. Respondent By: Shri R.R.N. Shukla, D.R. O R D E R This Appeal Has Been Preferred By The Assessee Against The Order Dated 25.05.2025, Passed By The National Faceless Appeal Centre, Delhi (Nfac) For Assessment Year 2017-18. 2.0 The Brief Facts Of The Case Are That The Assessee Was A Retired Assistant Engineer In The U.P. Power Corporation, Drawing Pension. The Assessee E-Filed His Return Of Income For The Year Under Consideration On 27.07.2017 Declaring A Total Income Of Rs.4,78,310/- After Claiming A Deduction Under Chapter Vi-A, Amounting To Rs.1,50,000/-. The Case Of The Assessee Was Selected For Limited Scrutiny Under The Computer Aided Scrutiny Selection (Cass) For The Reason Of ‘Cash Deposit During The Demonetization Period’. Accordingly, A Notice Under Section 143(2) Of The Income Tax Act, 1961 (Hereinafter Called

For Respondent: Shri R.R.N. Shukla, D.R
Section 115BSection 142(1)Section 143(2)Section 143(3)Section 69A

thereafter, observing that the assessee had not furnished any specific evidence explaining the source of cash deposits, proceeded to complete the assessment under section 143(3) of the Act, assessing the total income of the assessee at Rs.17,69,810/- after making an addition of Rs.12,91,500/- as unexplained

Assistant Commissioner of Income Tax, Central Circle-2, Ludhiana vs. Ritu Dhingra, Shakti Vihar, Haibowal Kalan, Ludhiana

In the result, the appeal of the Assessee and cross appeal of the Department are allowed for statistical purposes

ITA 862/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh07 Jan 2026AY 2019-20

Bench: him:- (a) That the assessment order dated 31.03.2023 passed u/s 143(3) r.w.s.153C is bad in law in as much no incriminating material was found suggesting any escapement of income at premises of Sh. Avtar Singh Kochhar. (b) That the assessment order passed is non-est and bad in law in as much the proceedings have not been conducted in the manner prescribed by the Department instructions from time to time which are mandatory for compliance by the Learned Authorities particularly with respect

For Appellant: Shri Ashwani Kumar, C.A and Ms. Deepali Aggarwal, C.AFor Respondent: Shri Rajat Kumar Kureel, CIT, DR
Section 131Section 132Section 143(3)Section 144Section 153CSection 153C(3)Section 153DSection 250Section 251(1)(a)

response to which the assessee filed return declaring the same income as originally returned. The assessment was completed under section 153C read with section 143(3) of the Act. 6.1 The Assessing Officer observed that incriminating digital material and WhatsApp chats seized during the search in the case of Shri ... invited our attention to the assessment order passed by the Assessing Officer, wherein the assessment was framed under section 153C read with section 143(3) of the Act. It was submitted that the approval granted by the competent authority also clearly records that the assessment proceedings were under section 153C

Ritu Dhingra, Ludhiana vs. Deputy Commissioner of Income Tax, Central Circle-2, Ludhiana

In the result, the appeal of the Assessee and cross appeal of the Department are allowed for statistical purposes

ITA 645/CHANDI/2025[2019-20]Status: DisposedITAT Chandigarh07 Jan 2026AY 2019-20

Bench: him:-

For Appellant: Shri Ashwani Kumar, C.A and Ms. Deepali Aggarwal, C.AFor Respondent: Shri Rajat Kumar Kureel, CIT, DR
Section 131Section 132Section 143(3)Section 144Section 153CSection 153C(3)Section 153DSection 250Section 251(1)(a)

response to which the assessee filed return declaring the same income as originally returned. The assessment was completed under section 153C read with section 143(3) of the Act. 6.1 The Assessing Officer observed that incriminating digital material and WhatsApp chats seized during the search in the case of Shri ... invited our attention to the assessment order passed by the Assessing Officer, wherein the assessment was framed under section 153C read with section 143(3) of the Act. It was submitted that the approval granted by the competent authority also clearly records that the assessment proceedings were under section 153C

Infinity International, Ahmedabad vs. NFAC, Delhi Present Juris. the ITO, Ward-3(3)(1), Ahmedabad

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

ITA 517/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 144Section 147Section 148Section 148ASection 250

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER

Infinity International, Ahmedabad vs. NFAC, Delhi Present Juris. the ITO, Ward-3(3)(1), Ahmedabad

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

ITA 462/AHD/2025[2014-15]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice-Shri Siddhartha Nautiyal

For Appellant: Shri S.N. Soparkar, Sr. AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 144Section 147Section 148Section 148ASection 250

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER

Blind Peoples Association India, Ahmedabad vs. The Dy.CIT, Circle-1(Exemption), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1959/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2016-17

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2016-17

For Appellant: Shri Nitin Pathak, A.RFor Respondent: Shri Amit Pratap Singh, Sr. D.R
Section 143(3)

THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “A” BENCH Before Dr. BRR Kumar, Vice President And Ms. Suchitra Kamble, Judicial Member

Ghcl Limited, Ahmedabad vs. The Dy.CIT, Central Circle-1(2), Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1643/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

For Appellant: Shri Tushar Hemani, Sr. AdvocateFor Respondent: Shri Prem Prakash Meena, CIT-DR
Section 115JSection 143(1)Section 153CSection 153DSection 154Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT SHRI T.R. SENTHIL KUMAR, JUDICIAL

Mamta Madha vs. Haran Agrawal, Ahmedabadvs.the ACIT, Circle-2(1)(1), Ahmedabad

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

ITA 1629/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2015-16

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

For Appellant: Shri Mohit Balani, ARFor Respondent: Shri Abhijit, Sr DR
Section 10Section 143(3)Section 154Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT SHRI T.R. SENTHIL KUMAR, JUDICIAL

Bhavnath Education Trust, Bavnagar vs. The ITO(Exemption) Ward, Bhavnagar

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

ITA 1559/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2018-19

Bench: Smt. Annapurna Guptaआयकर अपील सं./I.T.A. No. 1559/Ahd/2025 (िनधा"रण वष" / Assessment Year : 2018-19) बनाम/ Bhavnath Education Trust Income Tax Officer Bhanagar Highway, Dist. (Exemption) Vs. Bhavnagar, Ranghola- Ward, Bhavnagar 364230 / Aayakar Bhawan, Income Sanghavi & Company, Tax Office, Bhavanagar Prasham, 4Th Floor, Kasturba Road, Nr. Bilkha Plaza, Rajkot - 360001 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaatb2003J (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri M K Patel, Advocate ""यथ" क" ओर से/Respondent By : Smt. Mamta Singh, Sr. Dr Date Of Hearing 06/01/2026 07/01/2026 Date Of Pronouncement

For Appellant: Shri M K Patel, AdvocateFor Respondent: Smt. Mamta Singh, Sr. DR
Section 11(1)(a)Section 12ASection 143(3)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, AHMEDABAD BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER आयकर अपील सं./I.T.A. No

Assisstant Commissioner of Income Tax Circle-1(1)(1), Vadodara vs. Radhika Jewellers, Vadodara

In the result, the appeal filed by the Revenue is hereby dismissed

ITA 1263/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2013-14

Bench: DR. BRR Kumar (Vice President), Shri T. R. Senthil Kumar (Judicial Member)

Section 133ASection 271(1)(c)

IN THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “A” BENCH Before: DR. BRR Kumar, Vice President And Shri T. R. Senthil

Parvindar Indar Singh, Vadodara vs. The ACIT, Circle-1(1)(1), Vadodara

In the result, the appeal filed by the Assessee in ITA No

ITA 1002/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2013-14

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 147Section 14ASection 154

matter sought to be relied upon for purpose of reopening were very much before Assessing Officer at time when scrutiny assessment under section 143(3) was carried out - Instant case was not one of any omission or failure on part of assessee in fully and truly disclosing all relevant aspects ... aspects of matter sought to be relied upon for purpose of reopening were very much before Assessing Officer when scrutiny assessment under section 143(3) was carried out and no new tangible material could be said to have come to knowledge of Assessing Officer after framing of assessment - Whether therefore

Parvindar Indar Singh, Vadodara vs. The ACIT, Circle-1(1)(1), Vadodara

In the result, the appeal filed by the Assessee in ITA No

ITA 1001/AHD/2025[2013-14]Status: DisposedITAT Ahmedabad07 Jan 2026AY 2013-14

Bench: Smt. Annapurna Gupta (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)

Section 147Section 14ASection 154

matter sought to be relied upon for purpose of reopening were very much before Assessing Officer at time when scrutiny assessment under section 143(3) was carried out - Instant case was not one of any omission or failure on part of assessee in fully and truly disclosing all relevant aspects ... aspects of matter sought to be relied upon for purpose of reopening were very much before Assessing Officer when scrutiny assessment under section 143(3) was carried out and no new tangible material could be said to have come to knowledge of Assessing Officer after framing of assessment - Whether therefore

Mandar Rawool, Thane vs. ITO, Kudal

In the result, appeal of the Assessee is partly allowed

ITA 2099/PUN/2025[2022-23]Status: DisposedITAT Pune07 Jan 2026AY 2022-23

Bench: Dr.Dipak P. Ripote & Shri Vinay Bhamoreआयकर अपऩल सं. / Ita No.2099/Pun/2025 निर्धारण वषा / Assessment Year: 2022-23 Mandar Rawool, V The Income Tax 2107, L Wing, Bhoomi Acres S Officer, Kudal. Near Hiranandani Estate Internal Road, Opp Suraj Water Park, Kavesar, Thane – 400615 Pan:Attpr3716Q Appellant/ Assessee Respondent /Revenue Assessee By Shri Harshavardhan Vivek Bapat Revenue By Shri Ambarnath Khule – Jcit(Through Virtual) Date Of Hearing 25/11/2025 Date Of Pronouncement 07/01/2026 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Is An Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac], Passed Under Section 250 Of The Income Tax Act, 1961 For The A.Y.2022-23Dated 10.07.2025 Emanating From The Assessment Order Passed Under Section 143(3) Of The Act, Dated 22.03.2024.The Assessee Has Raised The Following Grounds Of Appeal :

Section 143Section 143(3)Section 153CSection 250Section 250(68)

Appeal)[NFAC], passed under section 250 of the Income Tax Act, 1961 for the A.Y.2022-23dated 10.07.2025 emanating from the Assessment Order passed under section 143(3) of the Act, dated 22.03.2024.The Assessee has raised the following grounds of appeal : ITA No.2099/PUN/2025 [A] “1. On the facts and in the circumstances ... that addition of on-money has been made in the case of V.R. Construction Private Limited for A.Y.2021-22 in the order passed under section 143(3) dated 31.12.2022. The relevant paragraph 5 of the assessment order is reproduced here as under : “5. Importantly, in the course of assessment proceedings

Dadaso Ashok Awati, Navi Mumbai vs. ITO, Ward-1, Sangli

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

ITA 1480/PUN/2025[2021-22]Status: HeardITAT Pune07 Jan 2026AY 2021-22

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2021-22

For Appellant: NoneFor Respondent: Shri Basavaraj Hiremath, Addl.CIT
Section 143(2)Section 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “A”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT AND SHRI VINAY