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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)

The Dy.Commissioner of Income-Tax, Jammu vs. M/S Fil Industries, Srinagar

In the result appeal of the assessee ground no 4 to 4

ITA 292/ASR/2015[2006-07]Status: DisposedITAT Amritsar24 Feb 2023AY 2006-07

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 32Section 43(1)Section 80I

learned Commissioner of Income Tax (Appeals) has grossly erred both on facts and in law, in confirming the order of assessment framed under section 143(3) framed by the Additional Commissioner of Income Tax, Range-3, Srinagar. 2. That the learned Commissioner of Income Tax (Appeals) has erred in sustaining

The Dy.Commissioner of Income-Tax, Jammu vs. M/S Fill Industries, Srinagar

In the result appeal of the assessee ground no 4 to 4

ITA 291/ASR/2015[2004-05]Status: DisposedITAT Amritsar24 Feb 2023AY 2004-05

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 32Section 43(1)Section 80I

learned Commissioner of Income Tax (Appeals) has grossly erred both on facts and in law, in confirming the order of assessment framed under section 143(3) framed by the Additional Commissioner of Income Tax, Range-3, Srinagar. 2. That the learned Commissioner of Income Tax (Appeals) has erred in sustaining

The Dy.Commissioner of Income-Tax, Jammu vs. M/S Fill Industries, Srinagar

In the result appeal of the assessee ground no 4 to 4

ITA 290/ASR/2015[2003-04]Status: DisposedITAT Amritsar24 Feb 2023AY 2003-04

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 32Section 43(1)Section 80I

learned Commissioner of Income Tax (Appeals) has grossly erred both on facts and in law, in confirming the order of assessment framed under section 143(3) framed by the Additional Commissioner of Income Tax, Range-3, Srinagar. 2. That the learned Commissioner of Income Tax (Appeals) has erred in sustaining

The Dy.Commissioner of Income-Tax, Jammu vs. M/S Fill Industries, Srinagar

In the result appeal of the assessee ground no 4 to 4

ITA 289/ASR/2015[2002-03]Status: DisposedITAT Amritsar24 Feb 2023AY 2002-03

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 32Section 43(1)Section 80I

learned Commissioner of Income Tax (Appeals) has grossly erred both on facts and in law, in confirming the order of assessment framed under section 143(3) framed by the Additional Commissioner of Income Tax, Range-3, Srinagar. 2. That the learned Commissioner of Income Tax (Appeals) has erred in sustaining

M/S Fil Industries Ltd, Srinagar vs. The Addl. Commissioner of Income Tax, Srinagar

In the result appeal of the assessee ground no 4 to 4

ITA 255/ASR/2015[2008-09]Status: DisposedITAT Amritsar24 Feb 2023AY 2008-09

Bench: Dr. M. L. Meena & Sh. Anikesh Banerjee

Section 143(3)Section 250Section 32Section 43(1)Section 80I

learned Commissioner of Income Tax (Appeals) has grossly erred both on facts and in law, in confirming the order of assessment framed under section 143(3) framed by the Additional Commissioner of Income Tax, Range-3, Srinagar. 2. That the learned Commissioner of Income Tax (Appeals) has erred in sustaining

Biowin Agro Research, Mananthawady vs. Income Tax Officer, Kozhikode

In the result, the assessee’s appeals are dismissed

ITA 3/COCH/2022[2018-2019]Status: DisposedITAT Cochin24 Feb 2023AY 2018-2019

Bench: Shri Sanjay Arora, Hon’Ble & Shri Sandeep Gosain, Hon'Ble

For Appellant: Ms. Krishna. K, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 11Section 12ASection 143(3)Section 2(15)Section 25Section 8

short) dismissing the assessee’s appeal against it’s assessments for Assessment Years (AYs.) 2017-18 (dated 30/12/2019) & 2018-19 (dated 20/4/2021) under section 143(3) of the Income Tax Act, 1961 (‘the Act’ hereinafter), vide orders dated 30/10/2021 & 08/11/2021 for the two consecutive years respectively 2. The issue arising

Biowin Agro Research, Mananthawady vs. Income Tax Officer, Kozhikode

In the result, the assessee’s appeals are dismissed

ITA 2/COCH/2022[2017-2018]Status: DisposedITAT Cochin24 Feb 2023AY 2017-2018

Bench: Shri Sanjay Arora, Hon’Ble & Shri Sandeep Gosain, Hon'Ble

For Appellant: Ms. Krishna. K, AdvocateFor Respondent: Smt. J.M. Jamuna Devi, Sr. DR
Section 11Section 12ASection 143(3)Section 2(15)Section 25Section 8

short) dismissing the assessee’s appeal against it’s assessments for Assessment Years (AYs.) 2017-18 (dated 30/12/2019) & 2018-19 (dated 20/4/2021) under section 143(3) of the Income Tax Act, 1961 (‘the Act’ hereinafter), vide orders dated 30/10/2021 & 08/11/2021 for the two consecutive years respectively 2. The issue arising

Sri.John Mathew N, Alappuzha vs. The ITO, WD-2, Alappuzha

In the result, the appeal by the assessee is dismissed

ITA 81/COCH/2018[2001-02]Status: DisposedITAT Cochin24 Feb 2023AY 2001-02

Bench: Shri Sanjay Arora & Shri Sandeep Gosainshri John Mathew N. The Income Tax Officer Neroth House Ward - 2, Alleppey Vs. No. 1, Jubilee Road Alappuzha [Pan: Acupm8885D] Appellant Respondent Appellant By: Shri Anil D. Nair & Shri P.K. Biju, Advocates Respondent By: Smt. J.M. Jamuna Devi, Sr. D.R. Date Of Hearing: 03.02.2023 Date Of Pronouncement: 24.02.2023 O R D E R Per Bench This Appeal By The Assessee Challenges The Validity Of The Reassessment Under Section 147 Read With Section 143(3) Of The Income Tax Act, 1961 (‘The Act’ Hereinafter) Dated 20.11.2007 For Assessment Year (Ay) 2001-02, Since Upheld In First Appeal Vide Order Dated 24.01.2018 By The Commissioner Of Income Tax (Appeals), Kottayam (‘Cit(A)’ For Short). 2.1 At The Outset, Shri Anil D. Nair, The Ld. Counsel For The Assessee-Appellant, Would Submit That The Basis Of The Assessee’S Challenge Is Two-Fold: (A) Non-Supply Of The Reasons Recorded; & (B) True & Full Disclosure Of All Material Facts Relating To The Income Escaping Assessment By The Assessee Per His Return Of Income.

For Appellant: Shri Anil D. Nair &For Respondent: Smt. J.M. Jamuna Devi, Sr. D.R
Section 143(2)Section 143(3)Section 147Section 148(2)Section 230ASection 234B

Bench This Appeal by the assessee challenges the validity of the reassessment under section 147 read with section 143(3) of the Income Tax Act, 1961 (‘the Act’ hereinafter) dated 20.11.2007 for assessment year (AY) 2001-02, since upheld in first appeal vide Order dated 24.01.2018 by the Commissioner

Shri Prashantsinh Ajitsinh Chauhan, Rajkot vs. The Pr. CIT-1, Rajkot

In the result, the appeal of the assessee is allowed

ITA 123/RJT/2022[2017-18]Status: HeardITAT Rajkot24 Feb 2023AY 2017-18

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

For Appellant: Shri R.K. Doshi, Ld. A.RFor Respondent: Shri Shramdeep Sinha, Ld. CIT-D.R
Section 143(3)Section 263

IN THE INCOME TAX APPELLATE TRIBUNAL RAJKOT BENCH, RAJKOT [CONDUCTED THROUGH VIRTUAL COURT ] Before: Shri Waseem Ahmed, Accountant Member And

Corus Vitrified Pvt. Ltd., Morbi vs. The Principal Commissioner of Income Tax - 1, Rajkot

In the result, the appeal of the assessee is allowed

ITA 119/RJT/2022[2017-18]Status: DisposedITAT Rajkot24 Feb 2023AY 2017-18

Bench: Shri Waseem Ahmed (Accountant Member), Shri Siddhartha Nautiyal (Judicial Member)

For Appellant: Shri Vimal Desai, A.RFor Respondent: Shri Shramdeep Sinha, Sr. D.R
Section 115BSection 143(3)Section 263Section 68Section 69C

case are that the assessee filed return of income for assessment year 2017-18 declaring total income at " Nil and the assessment under section 143(3) of the Act dated 31-12-2019 was finalised at an income of " 41,27,020/-. The PCIT observed that the assessee had made ... case were that respondent assessee has filed its return of income showing total income of Rs. 62,55,900/- which was assessed under section 143(3) of the Act, 1961 by an assessment order dated 14th March 2016. The respondent company received unsecured loans from M/s. Georgett Tradecom

The ACIT, Cen. Cir.-1, Rajkot-Gujarat vs. M/S. Siyaram Metal Udyog Pvt. Ltd., Jamnagar

ITA 373/RJT/2015[2011-12]Status: DisposedITAT Rajkot24 Feb 2023AY 2011-12

Bench: Shri Waseem Ahmed & Shri Siddhartha Nautiyal

For Appellant: Shri Sagar Shah, A.RFor Respondent: Shri Shramdeep Sinha, CIT DR
Section 132Section 143(3)Section 68

assessee against the order of the Ld. Commissioner of Income Tax (Appeals)-11, Ahmedabad arising in the matter of assessment order passed under Section 143(3) of the Income Tax Act, 1961 (here-in-after referred to as "the Act") relevant to the Assessment Years

Pareshbhai Harshadbhai Gohil, Surat vs. Dy. Commissioner of Income Tax, CC-2, Surat

In the result, ground of appeal raised by assessee is allowed

ITA 430/SRT/2022[2018-19]Status: DisposedITAT Surat24 Feb 2023AY 2018-19

Bench: Shri Pawan Singhita No. 424, 425, 426, 427, 428, 429 & 430/Srt/2022 (Assessment Years: 2012-13 To 2018-19) (Hearing In Physical Court) Pareshbhai Harshadbhai D.C.I.T., Gohel, Central Circle-2, Vs. 115, Ramkrupa Society, B/H Surat. Rachna Society, Kadodara, Surat-395006. Pan No. Aoepg 0254 L Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 144Section 153CSection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3). 6. The ld. CIT(A) after considering the submission of assessee held that it is a case where the assessee had totally ignored ... submits that the Coordinate Benches of the Tribunal in a series of decisions held that when the assessment has been made under Section 143(3) and not under Section 144, it means that subsequent compliance in the assessment proceedings was considered as a good compliance and the defaults committed earlier

Pareshbhai Harshadbhai Gohil, Surat vs. Dy. Commissioner of Income Tax, CC-2, Surat

In the result, ground of appeal raised by assessee is allowed

ITA 429/SRT/2022[2017-18]Status: DisposedITAT Surat24 Feb 2023AY 2017-18

Bench: Shri Pawan Singhita No. 424, 425, 426, 427, 428, 429 & 430/Srt/2022 (Assessment Years: 2012-13 To 2018-19) (Hearing In Physical Court) Pareshbhai Harshadbhai D.C.I.T., Gohel, Central Circle-2, Vs. 115, Ramkrupa Society, B/H Surat. Rachna Society, Kadodara, Surat-395006. Pan No. Aoepg 0254 L Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 144Section 153CSection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3). 6. The ld. CIT(A) after considering the submission of assessee held that it is a case where the assessee had totally ignored ... submits that the Coordinate Benches of the Tribunal in a series of decisions held that when the assessment has been made under Section 143(3) and not under Section 144, it means that subsequent compliance in the assessment proceedings was considered as a good compliance and the defaults committed earlier

Pareshbhai Harshadbhai Gohil, Surat vs. Dy. Commissioner of Income Tax, CC-2, Surat

In the result, ground of appeal raised by assessee is allowed

ITA 428/SRT/2022[2016-17]Status: DisposedITAT Surat24 Feb 2023AY 2016-17

Bench: Shri Pawan Singhita No. 424, 425, 426, 427, 428, 429 & 430/Srt/2022 (Assessment Years: 2012-13 To 2018-19) (Hearing In Physical Court) Pareshbhai Harshadbhai D.C.I.T., Gohel, Central Circle-2, Vs. 115, Ramkrupa Society, B/H Surat. Rachna Society, Kadodara, Surat-395006. Pan No. Aoepg 0254 L Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 144Section 153CSection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3). 6. The ld. CIT(A) after considering the submission of assessee held that it is a case where the assessee had totally ignored ... submits that the Coordinate Benches of the Tribunal in a series of decisions held that when the assessment has been made under Section 143(3) and not under Section 144, it means that subsequent compliance in the assessment proceedings was considered as a good compliance and the defaults committed earlier

Pareshbhai Harshadbhai Gohil, Surat vs. Dy. Commissioner of Income Tax, CC-2, Surat

In the result, ground of appeal raised by assessee is allowed

ITA 427/SRT/2022[2015-16]Status: DisposedITAT Surat24 Feb 2023AY 2015-16

Bench: Shri Pawan Singhita No. 424, 425, 426, 427, 428, 429 & 430/Srt/2022 (Assessment Years: 2012-13 To 2018-19) (Hearing In Physical Court) Pareshbhai Harshadbhai D.C.I.T., Gohel, Central Circle-2, Vs. 115, Ramkrupa Society, B/H Surat. Rachna Society, Kadodara, Surat-395006. Pan No. Aoepg 0254 L Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 144Section 153CSection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3). 6. The ld. CIT(A) after considering the submission of assessee held that it is a case where the assessee had totally ignored ... submits that the Coordinate Benches of the Tribunal in a series of decisions held that when the assessment has been made under Section 143(3) and not under Section 144, it means that subsequent compliance in the assessment proceedings was considered as a good compliance and the defaults committed earlier

Pareshbhai Harshadbhai Gohil, Surat vs. Dy. Commissioner of Income Tax, CC-2, Surat

In the result, ground of appeal raised by assessee is allowed

ITA 426/SRT/2022[2014-15]Status: DisposedITAT Surat24 Feb 2023AY 2014-15

Bench: Shri Pawan Singhita No. 424, 425, 426, 427, 428, 429 & 430/Srt/2022 (Assessment Years: 2012-13 To 2018-19) (Hearing In Physical Court) Pareshbhai Harshadbhai D.C.I.T., Gohel, Central Circle-2, Vs. 115, Ramkrupa Society, B/H Surat. Rachna Society, Kadodara, Surat-395006. Pan No. Aoepg 0254 L Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 144Section 153CSection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3). 6. The ld. CIT(A) after considering the submission of assessee held that it is a case where the assessee had totally ignored ... submits that the Coordinate Benches of the Tribunal in a series of decisions held that when the assessment has been made under Section 143(3) and not under Section 144, it means that subsequent compliance in the assessment proceedings was considered as a good compliance and the defaults committed earlier

Pareshbhai Harshadbhai Gohil, Surat vs. Dy. Commissioner of Income Tax, CC-2, Surat

In the result, ground of appeal raised by assessee is allowed

ITA 425/SRT/2022[2013-14]Status: DisposedITAT Surat24 Feb 2023AY 2013-14

Bench: Shri Pawan Singhita No. 424, 425, 426, 427, 428, 429 & 430/Srt/2022 (Assessment Years: 2012-13 To 2018-19) (Hearing In Physical Court) Pareshbhai Harshadbhai D.C.I.T., Gohel, Central Circle-2, Vs. 115, Ramkrupa Society, B/H Surat. Rachna Society, Kadodara, Surat-395006. Pan No. Aoepg 0254 L Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 144Section 153CSection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3). 6. The ld. CIT(A) after considering the submission of assessee held that it is a case where the assessee had totally ignored ... submits that the Coordinate Benches of the Tribunal in a series of decisions held that when the assessment has been made under Section 143(3) and not under Section 144, it means that subsequent compliance in the assessment proceedings was considered as a good compliance and the defaults committed earlier

Pareshbhai Harshadbhai Gohil, Surat vs. Dy. Commissioner of Income Tax, CC-2, Surat

In the result, ground of appeal raised by assessee is allowed

ITA 424/SRT/2022[2012-13]Status: DisposedITAT Surat24 Feb 2023AY 2012-13

Bench: Shri Pawan Singhita No. 424, 425, 426, 427, 428, 429 & 430/Srt/2022 (Assessment Years: 2012-13 To 2018-19) (Hearing In Physical Court) Pareshbhai Harshadbhai D.C.I.T., Gohel, Central Circle-2, Vs. 115, Ramkrupa Society, B/H Surat. Rachna Society, Kadodara, Surat-395006. Pan No. Aoepg 0254 L Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 144Section 153CSection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3). 6. The ld. CIT(A) after considering the submission of assessee held that it is a case where the assessee had totally ignored ... submits that the Coordinate Benches of the Tribunal in a series of decisions held that when the assessment has been made under Section 143(3) and not under Section 144, it means that subsequent compliance in the assessment proceedings was considered as a good compliance and the defaults committed earlier

Chandrakant Harshadbhai Gohel, Surat vs. Dy. Commissioner of Income Tax, Central Circle-2, Surat

In the result, ground of appeal raised by assessee is allowed

ITA 423/SRT/2022[2018-19]Status: DisposedITAT Surat24 Feb 2023AY 2018-19

Bench: Shri Pawan Singhita No. 417, 418, 419, 420, 421, 422 & 423/Srt/2022 (Assessment Years: 2012-13 To 2018-19) (Hearing In Physical Court) Chandrakant Harshadbhai D.C.I.T., Gohel, Central Circle-2, Vs. 115, Ramkrupa Society, Opp. Surat. Rachna Society, L.H Road, Varachha, Surat-395006. Pan No. Arnpg 3451 B Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 144Section 153Section 153CSection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3). 6. The ld. CIT(A) after considering the submission of assessee held that in spite of taking objection on initiation of assessment proceedings ... submits that the Coordinate Benches of the Tribunal in a series of decisions held that when the assessment has been made under Section 143(3) and not under Section 144, it means that subsequent compliance in the assessment proceedings was considered as a good compliance and the defaults committed earlier

Chandrakant Harshadbhai Gohel, Surat vs. Dy. Commissioner of Income Tax, Central Circle-2, Surat

In the result, ground of appeal raised by assessee is allowed

ITA 422/SRT/2022[2017-18]Status: DisposedITAT Surat24 Feb 2023AY 2017-18

Bench: Shri Pawan Singhita No. 417, 418, 419, 420, 421, 422 & 423/Srt/2022 (Assessment Years: 2012-13 To 2018-19) (Hearing In Physical Court) Chandrakant Harshadbhai D.C.I.T., Gohel, Central Circle-2, Vs. 115, Ramkrupa Society, Opp. Surat. Rachna Society, L.H Road, Varachha, Surat-395006. Pan No. Arnpg 3451 B Appellant/ Assessee Respondent/ Revenue

Section 132Section 142(1)Section 143(3)Section 144Section 153Section 153CSection 254(1)Section 271(1)(b)Section 272A(1)(d)Section 274

should not be considered as default for penalizing the assessee. Otherwise the assessee always co-operated during the assessment and finally order under Section 143(3). 6. The ld. CIT(A) after considering the submission of assessee held that in spite of taking objection on initiation of assessment proceedings ... submits that the Coordinate Benches of the Tribunal in a series of decisions held that when the assessment has been made under Section 143(3) and not under Section 144, it means that subsequent compliance in the assessment proceedings was considered as a good compliance and the defaults committed earlier