“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)

Zarah Rafique Malik, Mumbai vs. ITO (Int Tax) Ward-3(2)(1), Mumbai

ITA 5159/MUM/2025[2022-23]Status: DisposedITAT Mumbai10 Mar 2026AY 2022-23

Bench: Justice (Retd.) C V Bhadang, Hon’Ble & Shri Vikram Singh Yadav, Hon’Blezarah Rafique Malik Income Tax Officer, (Int.Tax) B/1703, Vivarea Condominium, Ward- 3(2)(1), Mumbai Vs. Sane Guruji Marg, Jacob Circle, Mahalaxmi East Mumbai – 400 011 Pan : Adcpm8960G (Appellant) (Respondent)

For Appellant: Shri K Gopal, Adv. & Shri Oom KandalkarFor Respondent: Shri Krishna Kumar, Sr. DR

Section 120(4)(b)Section 127Section 143(2)Section 143(3)Section 144BSection 153(1)

Hence, the said assessment order is time barred and therefore, bad in law. 4. The final assessment order dated 15.07.2025 passed under section 143(3) r.w.s. 144C(13) of the Act is unlawful and without jurisdiction as the same is in contravention of the law laid down

Dy.Commissioner of Income Tax, Mumbai vs. Bp India Pvt Ltd, Mumbai

In the result, appeal of the Revenue is dismissed

ITA 4907/MUM/2025[2011-12]Status: DisposedITAT Mumbai10 Mar 2026AY 2011-12

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2011-12 Deputy Commissioner Of Bp India Pvt. Ltd. Income Tax , Circle-1(2)(1), P B No 19411, Mumbai Vs. Technopolis Knowledge Park, Andheri, Mumbai - 400043 (Pan: Aaccb2030Q) (Appellant) (Respondent) C.O. No. 276/Mum/2025 Assessment Year: 2011-12 Bp India Pvt. Ltd. Deputy Commissioner Of Income P B No 19411, Tax , Circle-1(2)(1), Technopolis Knowledge Park, Vs. Mumbai Andheri, Mumbai - 400043 (Pan: Aaccb2030Q) (Appellant) (Respondent) Present For: Assessee : Ms. Chandni Shah, Mr. Amol Mahajan & Ms. Nidhi Agarwal, Cas Revenue : Shri Bhagirath Ramawat, Sr. Dr Date Of Hearing : 18.12.2025 Date Of Pronouncement : 10.03.2026 O R D E R Per Girish Agrawal: This Appeal Filed By The Revenue & Cross Objection Filed By The Assessee Against The Order Of Cit (A) 55, Mumbai, Vide Order No. Itba/Apl/S/250/2025-26/1076574916(1), Dated 30/05/2025, Passed Against The Assessment Order By Acit - 9(2)(1), Mumbai, U/S. 143(3) R.W.S 144(C)(3)(B) Of The Income-Tax Act (Hereinafter Referred To As The “Act”), Dated 13.04.2015, For Assessment Year 2011-12. 2

For Appellant: Ms. Chandni Shah, Mr. Amol Mahajan and Ms. Nidhi Agarwal, CAsFor Respondent: Shri Bhagirath Ramawat, Sr. DR

Section 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL “K” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT

Asst. Commissioner of Income Tax, Mumbai vs. Reliance Retail Limited, Mumbai

In the result, the appeal filed by the Revenue is dismissed, whereas the appeal filed by the assessee is partly allowed

ITA 4244/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 135Section 143(3)Section 144BSection 14ASection 250Section 37(1)Section 80GSection 80JSection 92C

Income-tax Act, 1961 [hereinafter referred to as “the Act”] in relation to the assessment framed by the Assessing Officer under section 143(3) read with section 144B of the Act vide order dated 27.09.2022. Facts of the Case 2. The assessee is a company engaged in the business ... passed an order dated 27.01.2022 without proposing any adjustment to the arm’s length price. 3. The assessment was completed under section 143(3) read with section 144B of the Act vide order dated 27.09.2022. During following additions and disallowances: i. Disallowance of deduction under section 80G The Assessing Officer

Reliance Retail Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 8(1)(1), Mumbai

ITA 3510/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

Section 135Section 143(3)Section 144BSection 14ASection 250Section 37(1)Section 80GSection 80JSection 92C

Income-tax Act, 1961 [hereinafter referred to as "the Act"] in relation to the assessment framed by the Assessing Officer under section 143(3) read with section 144B of the Act vide order dated 27.09.2022. Facts of the Case 2. The assessee is a company engaged in the business ... passed an order dated 27.01.2022 without proposing any adjustment to the arm's length price. 3. The assessment was completed under section 143(3) read with section 144B of the Act vide order dated 27.09.2022. During the course of assessment proceedings, the Assessing Officer examined various claims made

Prodigy Infomatics Private Limited, Mumbai vs. ITO, 15(2)(4), Mumbai

Accordingly, these grounds are dismissed

ITA 2124/MUM/2025[2012-13]Status: DisposedITAT Mumbai10 Mar 2026AY 2012-13

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Jagadishprodigy Infomatics Private Vs. Ito, 15(2)(4), Mumbai Limited Director Ito, 15(2)(4), Mumbai Plot No. D- 388, Midc, Ttc Aayakar Bhavan Industrial Area, Kukshet Mumbai- 400020 Village, Navi Mumbai - 400705 Pan/Gir No. Aadcp3211A (Applicant) (Respondent) Assessee By None Revenue By Shri Virabhadra Mahajan, (Sr. Dr) Date Of Hearing 04.03.2026 Date Of Pronouncement 10.03.2026 आदेश / Order Per Sandeep Gosain, Jm: The Present Appeal Has Been Filed By The Assessee Challenging The Impugned Order 18.02.2025 Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), By The National Faceless Appeal Centre, Delhi (Nfac) For The Assessment Year 2012-13. The Following Grounds Are Reproduced Below: “1. On The Facts & In The Circumstances Of The Case & In Law, The Learned C.I.T. (A) Erred In Dismissing The Appeal.

Section 250Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH MUMBAI BEFORE HON’BLE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & HON’BLE SHRI

Dy. Commissioner of Income Tax, Circle-1, Thane, Wagle Industrial Estate, Thane West vs. M M Plastoware India Private Limited, Thane

In the result, appeal of the Revenue is dismissed and cross objection of the assessee is allowed

ITA 133/MUM/2025[2016-17]Status: DisposedITAT Mumbai10 Mar 2026AY 2016-17

Bench: Shri Pawan Singh & Shri Girish Agrawalassessment Year: 2016-17 Deputy Commissioner Of M M Plastoware India Private Income Tax, Circle-1, Thane Limited Gala No. 10-15, Arihant Darshan, Vs. 90 Feet Road, Bhayander West, Thane – 101101. (Pan: Aahcm2568D) (Appellant) (Respondent) C.O. No. 120/Mum/2025 Assessment Year: 2016-17 M M Plastoware India Private Deputy Commissioner Of Income Limited Tax, Circle-1, Thane Gala No. 10-15, Arihant Darshan, 90 Feet Road, Vs. Bhayander West, Thane – 101101. (Pan: Aahcm2568D) (Appellant) (Respondent) Present For: Assessee : Shri Lalit Munoyat, Ca Revenue : Shri Bhagirath Ramawat, Sr. Dr Date Of Hearing : 22.12.2025 Date Of Pronouncement : 10.03.2026 O R D E R Per Girish Agrawal:

For Appellant: Shri Lalit Munoyat, CAFor Respondent: Shri Bhagirath Ramawat, Sr. DR

Section 143(3)Section 254Section 32(1)(ila)

IN THE INCOME TAX APPELLATE TRIBUNAL “K(SMC)” BENCH MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL

Upsrtc Emp Salary Person Co-Op Lone Samiti Limited, Haridwar vs. ITO, Circle1(3)(1), Haridwar

In the result, the appeal of the assessee is allowed

ITA 2/DDN/2026[2017-18]Status: HeardITAT Dehradun09 Mar 2026AY 2017-18

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2017-18] Upsrtcc Emp. Salary Vs Ito Person Co-Op Loan Samiti Ward-1(3)(3) Ltd., Haridwar Bus Stand, Haridwar Haridwar, Uttarakhand Uttarakhand Pan-Aaaau9031C Appellant Respondent Appellant By Shri Rajiv Sahni, Ca Respondent By Shri Amar Pal Singh, Sr.Dr Date Of Hearing 09.03.2026 Date Of Pronouncement 09.03.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 04.12.2025 Passed By Ld. Commissioner Of Income Tax (A)/Addl/Jcit(A)-10, Mumbai [“Ld. Cit(A)”] U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of Assessment Order Dated 29.11.2019 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2017-18. 2. Before Us, Ld.Ar For The Assessee Submits That During The Period Of Demonetization, Assessee Society Has Deposited 12,98,000/- In Specified Bank Notes (“Sbn”) Which Was Claimed To Have Been Received As Recovery Of The Loans From Its Members However, The Ao Has Made The Addition By Treating The Same As Unexplained Money. Ld.Ar Further Submits That Entire Sum Was Received As A Recovery Of Loans Given To Its Members & Necessary Copy Of Cash Book Alongwith Cash Flow Statement Was Submitted However, These Were Not Appreciated By Ao But Ld. Cit(A) Had Allowed The Part Relief Of Inr 8,30,000/- & Sustained The Balance Amount. Ld.Ar Submits That Sole Basis For Confirming The Addition Is Non-Production Of The Receipts. Ld.Ar Submits That Once The Books Of Accounts Have Been Accepted Wherein Cash Received From Members Is Duly Recorded, No Addition Is Required To Be Made. He Prayed Accordingly.

Section 143(3)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL DEHRADUN CIRCUIT BENCH: DEHRADUN BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT & SHRI MANISH AGARWAL, ACCOUNTANT

Daya Thourani, Raipur vs. Income Tax Officer, Ward-3(1), Raipur

In the result, appeal of the assessee is allowed as per afore-stated terms

ITA 1/RPR/2026[2017-18]Status: DisposedITAT Raipur09 Mar 2026AY 2017-18

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita No.1/Rpr/2026 "नधा"रण वष" /Assessment Year : 2017-18 Daya Thourani Thourani Niwas, Near Mla Rest House, Tagore Nagar, Raipur-492 001 (C.G.) Pan: Ablpt6191R

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR

Section 143(2)Section 143(3)Section 151Section 282Section 282A(1)

आयकर अपील"य अ"धकरण "यायपीठ “एक-सद"य” मामला रायपुर म" IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH