“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)

Aptive Components India P.Ltd (Formerly Known As M/S Delphi Automotive Systems Pvt. Ltd.), New Delhi vs. DCIT Circle-3(1), New Delhi

In the result, appeal of the assessee in respect of ground no

ITA 1129/DEL/2020[2005-06]Status: DisposedITAT Delhi19 Dec 2025AY 2005-06

Bench: Shri Challa Nagendra Prasad & Shri Brajesh Kumar Singh[Assessment Year: 2005-06] M/S Aptiv Components India Deputy Commissioner Of Income Private Limited Tax, (Formerly Known As M/S Delphi Vs Circle-3(1), Automotive Systems Pvt. Ltd.) Room No.-380B, C.R. Building P-24, Green Part Extn., Delhi- I.P. Estate, 110016. Delhi-110002. Pan- Aaacd0226E Assessee Revenue

Section 10ASection 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, F: NEW DELHI BEFORE SHRI CHALLA NAGENDRA PRASAD, JUDICIAL MEMBER AND SHRI

Shring Construction Company Pvt. Ltd., Dehradun vs. DCIT, Circle-2, Muzaffarnagar

In the result, the appeal filed by the Assessee stands allowed

ITA 7056/DEL/2018[2011-12]Status: DisposedITAT Delhi19 Dec 2025AY 2011-12

Bench: Shri Mahavir Singh, Hon’Ble & Shri Brajesh Kumar Singh, Hon’Blea.Y. : 2011-12

For Appellant: Sh. Ankit Gupta, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR

Section 143(3)Section 271Section 271(1)(c)Section 274

IN THE INCOME TAX APPELATE TRIBUNAL DELHI BENCH “F”: NEW DELHI BEFORE SHRI MAHAVIR SINGH, HON’BLE VICE PRESIDENT AND

Puri Oil Mills Ltd., New Delhi vs. DCIT, Circle- 20(1), New Delhi

In the result, appeal of the assessee is allowed

ITA 1681/DEL/2018[2014-15]Status: DisposedITAT Delhi19 Dec 2025AY 2014-15

Bench: Vikas Awasthy & Shri Brajesh Kumar Singh

Section 143(2)Section 143(3)Section 2(24)Section 44Section 44ASection 5

Delhi, dated 05.01.2018 [hereinafter referred to as the ‘Ld. CIT(A)’] arising out of the assessment order dated 26.12.2016 order passed under Section 143(3) of the Income Tax Act, 1961 ITA No.- 1681/Del/2018 Puri Oil Mills Ltd. (hereinafter referred to as ‘the Act’) passed by the DCIT, Circle

Shailesh Chandra Shukla, Etawah vs. ITO Ward-2(2)(5), Etawah

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

ITA 493/AGR/2025[2021-22]Status: DisposedITAT Agra18 Dec 2025AY 2021-22

Bench: Shris.Rifaur Rahmanshailesh Chandra Shukla, Vs. Ito, Ward 2(2)(5), 192-C, Friends Colony, Etawah. Etawah – 206 001 (Uttar Pradesh). (Pan : Ahwps1502Q) (Appellant) (Respondent) Assessee By : None Revenue By : Shri Shailender Shrivastava, Sr. Dr Date Of Hearing : 18.12.2025 Date Of Order : 18.12.2025 O R D E R 1. This Appeal Is Filed By The Assessee Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi Dated 14.08.2025 For Assessment Year 2021-22. 2. None Appeared On Behalf Of The Assessee. I Proceeded To Adjudicate The Issue With The Assistance Of Ld. Dr Of The Revenue. 3. At The Time Of Hearing, It Was Observed That That The Ld. Cit (A) Decided The Issue Against The Assessee By Observing That Assessee Has Not Pursued The Appeal Despite Being Granted Several Opportunities & The Details Are Given In The First Appellate Order & Dismissed The Appeal. It Is Observed That Ld. Cit (A) Has Not Decided The Issue Ex-Parte & Affirmed The Order Of The Assessing

For Appellant: NoneFor Respondent: Shri Shailender Shrivastava, Sr. DR

Section 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL AGRA BENCH ‘SMC’: AGRA BEFORE SHRIS.RIFAUR RAHMAN, ACCOUNTANT MEMBER Shailesh Chandra Shukla, vs. ITO

Sarif, Jalesar Etah vs. Assessing Officer, Ward-4(3)(1), Etah

In the result, both the appeals ITA Nos

ITA 464/AGR/2025[2014-15]Status: DisposedITAT Agra18 Dec 2025AY 2014-15

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 142(1)Section 143(3)Section 144Section 147Section 148Section 250Section 271(1)(c)Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL, AGRA BENCH, AGRA BEFORE : SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI SUNIL KUMAR

Sarif, Jalesar, Etah vs. Assessin Officer, Ward-4(3)(1), Dinesh Nagar Etah

In the result, both the appeals ITA Nos

ITA 463/AGR/2025[2014-15]Status: DisposedITAT Agra18 Dec 2025AY 2014-15

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singh

Section 142(1)Section 143(3)Section 144Section 147Section 148Section 250Section 271(1)(c)Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL, AGRA BENCH, AGRA BEFORE : SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI SUNIL KUMAR

Bhoj Raj, Agra vs. Ward 1(1)(1), Agra

In the result, appeal filed by the assessee is allowed

ITA 436/AGR/2025[2017-2018]Status: DisposedITAT Agra18 Dec 2025AY 2017-2018

Bench: : Shri S. Rifaur Rahmanassessment Year: 2017-18

Section 142(1)Section 143(3)Section 147Section 148Section 151Section 69A

Since the assessee has not disclosed fully and truly all material facts necessary for assessment, the assessment was completed u/s. 147 read with section 143(3) of the Income-tax Act, 1961 (“the Act” for short) on 28.09.2021 at a total income of Rs.88,59,618/-. Aggrieved with the above

Sharad Sarawgi, Giridih vs. ACIT, C. C., Dhanbad

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

ITA 424/RAN/2024[2021-22]Status: DisposedITAT Ranchi18 Dec 2025AY 2021-22

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.424/Ran/2024 Assessment Year: 2021-22 Sharad Sarawgi….... …………….…….…............................……….……Appellant Sarawgi Sadan, Dumri Road, Giridih, Jharkhand- 815301. [Pan: Acspj2613G] Vs. Acit, C.C-Dhanbad………….....….…..….........……........……...…..…..Respondent Appearances By: Shri Devesh Poddar, Ar, Appeared On Behalf Of The Appellant. Shri Sumit Dasgupta, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 11, 2025 Date Of Pronouncing The Order : December 18, 2025 Order Per Sonjoy Sarma: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ci(A)-3, Patna (Hereinafter Referred To As “Ld. Cit(A)”) Dated 12.09.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Is Part Of The Saraogi Group. A Search & Seizure Operation Under Section 132(1) Of The Income-Tax Act, 1961 Was Conducted On The Group On Various Dates, Along With A Survey Under Section 133A Of The Act At Certain Business Premises Of The Group. During The Course Of Search, Cash Aggregating To ₹2,15,50,000 Was Found From The Bedroom Of Shri Santosh Kumar Saraogi. In The Statement Recorded Under Section 132(4), It Was Stated That Cash Of ₹21,20,000 Belonged To The Present Assessee, While The Balance Amount Belonged To Other Concerns. The Assessee Filed Its Return Of Income Under Section 139(1) For Ay 2021–22 Declaring Total Income Of ₹4,66,180. Subsequently, Notices Under Sections 143(2) & 142(1) Were

Section 131Section 132(1)Section 132(4)Section 133ASection 139(1)Section 143(3)Section 153ASection 250Section 69A

hands of the assessee under section 69A of the Act, while completing assessment under section 153A read with section 143(3) of the Act. 3. Aggrieved, the assessee carried the matter in appeal before the Ld. CIT(A), who dismissed the appeal and confirmed the order of the Assessing Officer

Karan Jain, Mumbai vs. Deputy Commissioner of Income Tax, Circle-1, Guwahati

In the result, the all the appeals of the assessees are allowed

ITA 310/GTY/2019[2015-16]Status: DisposedITAT Guwahati18 Dec 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri Santosh Kumar Karnani

Section 132Section 143(2)Section 153ASection 153D

duly issued. 5. Thereafter, on 30.12.2018, an assessment order was passed by the assessing officer ["AO"] under Section 153A read with Section 143(3) of the Act, whereby, the total taxable income of the assessee was pegged at ₹5,19,85,970/-. Being aggrieved by the additions made

Karishma Jain, Mumbai vs. Deputy Commissioner of Income Tax, Circle-1, Guwahati

In the result, the all the appeals of the assessees are allowed

ITA 309/GTY/2019[2016-17]Status: DisposedITAT Guwahati18 Dec 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri Santosh Kumar Karnani

Section 132Section 143(2)Section 153ASection 153D

Karishma Jain, Mumbai vs. Deputy Commissioner of Income Tax, Circle-1, Guwahati

In the result, the all the appeals of the assessees are allowed

ITA 308/GTY/2019[2015-16]Status: DisposedITAT Guwahati18 Dec 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri Santosh Kumar Karnani

Section 132Section 143(2)Section 153ASection 153D

Reshmi Jain, Mumbai vs. Deputy Commissioner of Income Tax, Circle-1, Guwahati

In the result, the all the appeals of the assessees are allowed

ITA 307/GTY/2019[2016-17]Status: DisposedITAT Guwahati18 Dec 2025AY 2016-17

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri Santosh Kumar Karnani

Section 132Section 143(2)Section 153ASection 153D

Reshmi Jain, Mumbai vs. Deputy Commissioner of Income Tax, Circle-1, Guwahati

In the result, the all the appeals of the assessees are allowed

ITA 306/GTY/2019[2015-16]Status: DisposedITAT Guwahati18 Dec 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Manomohan Das, Jm

For Appellant: Shri Somnath Ghosh, ARFor Respondent: Shri Santosh Kumar Karnani

Section 132Section 143(2)Section 153ASection 153D

Belong Tracom Private Limited, Kolkata vs. Income Tax Officer, Ward-2(1), Dibrugahr

In the result, the appeal of the assessee is allowed

ITA 254/GTY/2019[2011-12]Status: DisposedITAT Guwahati18 Dec 2025AY 2011-12

Bench: Shri Rajesh Kumar, Am & Shrimanomohan Das, Jm Belong Tracom Private Limited Income Tax Officer, Ward 2(1) 3, Mullick Street, Kolkata- C.R. Building, Mancotta Road, Vs. 700007, West Bengal Dibrugarh-786008, Assam (Appellant) (Respondent) Pan No. Aaecb0435D Assessee By : Shri Miraj D Shah, Ar Revenue By : Shri Kausik Ray, Dr Date Of Hearing: 18.09.2025 Date Of Pronouncement: 18.12.2025

For Appellant: Shri Miraj D Shah, ARFor Respondent: Shri Kausik Ray, DR

Section 143(1)Section 143(3)Section 147Section 148Section 68

raised in ground no.1 is against the validity of notice issued u/s 148 of the Act and assessment framed u/s 147 read with section 143(3) of the Act by the ld. AO which are otherwise bad in law. 2.1. The facts in brief are that the assessee filed ... nonetheless the Assessing Officer though referred to the information received from the Investigation department, while completing the assessment under section 147 read with section 143(3) has clearly abandoned those reasons and proceeded on a different footing. Before the first appellate Authority, the assessee specifically raised the issue that

Damodar Mangalji & Company Limited, Panaji vs. Assistant Commissioner of Income Tax, Circle - 1(1), Panaji

Appeals stands DISMISSED

ITA 35/PAN/2025[2014-15]Status: DisposedITAT Panaji18 Dec 2025AY 2014-15

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliita Nos. 034 & 035/Pan/2025 Assessment Year : 2011-12 & 2014-15 Damodar Mangalji & Company Ltd. Damodar Niwas, 1St Floor, Mc Road, Panaji, Goa-403001. Pan : Aaacd6880G . . . . . . . Appellant V/S Jt./Asstt. Commissioner Of Income Tax, Range-1/Circle-1(1), Goa. . . . . . . . Respondent Appearances Assessee By : Adv Rahul Sarda [‘Ld. Ar’] Revenue By : Mr M Satish [‘Ld. Dr’] Date Of Conclusive Hearing : 20/11/2025 Date Of Pronouncement : 18/12/2025 Order Per G. D. Padmahshali; The Captioned Twin Appeals Of Assessee Instituted U/S 253(1) Of The Income-Tax Act, 1961 [‘The Act’] Are Directed Against Separate Din & Order 1070138041(1) Dt. 08/11/2024 & 1070321994(1) Dt. 13/11/2024 Passed U/S 250 Of The Act By National Faceless Appeal Centre, Delhi [‘Ld. Nfac/Cit(A)’] Which Sprang From Assessment Orders Passed U/S 143(3) Of The Act Anent To Assessment Years 2011-12 & 2014-15 [‘Ay’].

For Appellant: Adv Rahul Sarda [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]

Section 143(1)Section 143(3)Section 14ASection 250Section 253(1)Section 253(3)Section 37(1)Section 40(1)(i)

IN THE INCOME TAX APPELLATE TRIBUNAL, PANAJI BENCH, GOA BEFORE HON’BLE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND SHRI

Damodar Mangalji & Company Limited, Panaji vs. The Joint Commissioner of Income Tax, Range - 1, Panaji

Appeals stands DISMISSED

ITA 34/PAN/2025[2011-12]Status: DisposedITAT Panaji18 Dec 2025AY 2011-12

For Appellant: Adv Rahul Sarda [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]

Section 143(1)Section 143(3)Section 14ASection 250Section 253(1)Section 253(3)Section 37(1)Section 40(1)(i)

IN THE INCOME TAX APPELLATE TRIBUNAL, PANAJI BENCH, GOA BEFORE HON’BLE SHRI PAVAN KUMAR GADALE, JUDICIAL MEMBER AND SHRI

Kanaiyalal Hemendra Vyas, Dhoraji vs. ITO Ward 2(2)(1) Rajkot, Aayakar Bhavan

In the result, these two appeals of the assessee (In ITA 306&

ITA 307/RJT/2023[2011-12]Status: DisposedITAT Rajkot18 Dec 2025AY 2011-12

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 306 & 307/Rjt/2023 (निर्धररणवध/ Assessment Year: (2010-11 & 2011-12) (Hybrid Hearing) Kanaiyalal Hemendra Vyas Vs. The Income Tax Officer, Wd – Sudhrai Colony, Station Road, Nr. 2(2)(1), Aayakar Bhavan, Race Railway Station, Dhoraji (Guj) - 360410 Course Ring Road, Rajkot - 360001 स्यीलेख्सं./जीआइआरसं./Pan/Gir No.: Akypv3966G (Appellant) (Respondent) Appellant By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Cit(Dr) Date Of Hearing : 25/09/2025 Date Of Pronouncement : 18/12/2025 आदेश/ O R D E R Per Dinesh Mohan Sinha, Jm:

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. CIT(DR)

Section 143(3)Section 147Section 250Section 44ASection 69B

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN

Kanaiyalal Hemendra Vyas, Dhoraji vs. Income Tax Office, Ward - 2(2)(1), Rajkot, Aayakar Bhavan

In the result, these two appeals of the assessee (In ITA 306&

ITA 306/RJT/2023[2010-11]Status: DisposedITAT Rajkot18 Dec 2025AY 2010-11

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. CIT(DR)

Section 143(3)Section 147Section 250Section 44ASection 69B

IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN LAL SAINI, ACCOUNTANT MEMBER AND SHRI DINESH MOHAN

ACIT, Central Circle - 2(1), Ahmedabad vs. Vrindavan Furnishing Private Limited., Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 264/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad18 Dec 2025AY 2018-19

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaassessment Year: 2018-19

Section 131Section 143(3)Section 147Section 148Section 68

Income tax (Appeals)-12, Ahmedabad (in short “the CIT(A)”) dated 05.12.2024 for the Assessment Year (A.Y.) 2018-19 in the proceeding under Section 143(3)/147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’). 2. The brief facts of the case are that the assessee

Mono Steeel (India) Limited, Mumbai vs. The Dy. CIT, Circle-2(1)(1), Ahmedabad

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

ITA 1648/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad18 Dec 2025AY 2015-16

Bench: Dr.Brr Kumar & Shri Siddhartha Nautiyal

For Appellant: Shri Mohit Balani, A.RFor Respondent: Shri R P Rastogi, CIT. DR

Section 143(2)Section 143(3)Section 144Section 144BSection 144B(9)Section 147Section 148Section 80

company which filed its return of income declaring a total income of Rs. 13,76,41,770/-. The assessment was originally completed under section 143(3) of the Act on 05.12.2018, determining the total income at Rs. 26,83,75,625/-. On scrutiny of the assessment records, the learned Assessing