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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)

Savita Mitkari, Pune vs. Income Tax Officer, Pune

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

ITA 2193/PUN/2025[2011-12]Status: DisposedITAT Pune28 Nov 2025AY 2011-12

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.2193/Pun/2025 निर्धारण वर्ष / Assessment Year: 2011-12 Savita Mitkari, V The Income Tax Officer, Flat No.302, G4, Gangadham S Pmt Phase Ii, Market Yard, Building Pune 411037. Commercial Complex, Swargate, Pune 411037. Pan: Arppm8052L Appellant/ Assessee Respondent / Revenue Assessee By Ca Sagar Kale Shri Arvind Renge – Addl.Cit(Dr) Revenue By Date Of Hearing 06/11/2025 Date Of Pronouncement 28/11/2025 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.2011-12 Dated 30.07.2025 Emanating From The Assessment Order Passed Under Section 143(3) R.W.S 147 Of The Act, Dated 30.12.2018. The Assessee Has Raised The Following Grounds Of Appeal :

Section 143(3)Section 147Section 250Section 68

NFAC] passed under section 250 of the Income Tax Act, 1961 for the A.Y.2011-12 dated 30.07.2025 emanating from the Assessment Order passed under section 143(3) r.w.s 147 of the Act, dated 30.12.2018. The Assessee has raised the following grounds of appeal : ITA No.2193/PUN/2025 [A] “The appellant is an individual ... income and other sources of income. The case was subsequently reopened under Section 147 of the Income Tax Act, 1961 and reassessed under Section 143(3) read with Section 147. The Assessing Officer made additions of *10,00,000 as unexplained unsecured loan under Section

Shree Vishal Jewellers, Pune vs. DCIT Circle 9 Pune, Akurdi Pune

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

ITA 1975/PUN/2025[2017-18]Status: DisposedITAT Pune28 Nov 2025AY 2017-18

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1975/Pun/2025 धििाारण वर्ा / Assessment Year : 2017-18 Shree Vishal Jewellers, Dcit, Circle-9, Pune Kohinoor Arcade, Nigdi, Pune-411044 Vs. Pan : Achfs8052R अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Shri Sushant Padhye Department By : Shri Udaya Bhaskar Jakke Date Of Hearing : 11-11-2025 Date Of 28-11-2025 Pronouncement : आदेश / Order Per Astha Chandra, Jm : The Appeal Filed By The Assessee Is Directed Against The Order Dated 14.07.2025 Of The Ld. Commissioner Of Income Tax (Appeals), Nfac, Delhi [“Cit(A)/Nfac”] Pertaining To Assessment Year (“Ay”) 2017-18. 2. The Assessee Has Raised The Following Grounds Of Appeal :- “1. Error In Additions Of Rs.6,25,94,300/- In Respect Of Provision Of Section 68 Of The Act. The Ao Erred In Appreciating The Complexity Of Assessee'S Business & Made Addition Based On Conjecture Rather Than Evidence. Addition Was Made Merely By Treating Excess Balance Of Cash As Unexplained Credits Thereby Ignoring The Circumstances In Which Such Cash Was Recorded. 2. Error In Additions Of Rs.82,96,610/- In Respect Of Provision Of Section 68 Of The Act. The Ao Made An Addition In Haste Without Completely Understanding The Facts Of The Case. This Addition Belies A Sense Of Proportion. A. Addition Of Rs.46,96,610/- Of Unsecured Loan Forwarded By Mrs. Sangeeta Sonigara: The Officer Erred In Appreciating The Fact That The Loan Could Have Been Given By The Said Person From Gifts Received Or Through Other Exempt Income Earned In The Past. Merely Because The Person Doesnt Not Have Sufficient Income In The Immediately Previous Years Does Not Invalidate The Genuineness Of The Unsecured Loan. B. Addition Of Rs.37,00,000/- Of Unsecured Loan Forwarded By Mr. Ganesh Nadha: The Said Person Is A Third Party. Unsecured

For Appellant: Shri Sushant PadhyeFor Respondent: Shri Udaya Bhaskar Jakke
Section 143(2)Section 143(3)Section 250Section 68

आयकर अपीलीय अधिकरण “बी” न्यायपीठ पुणे में । IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, PUNE BEFORE SHRI R.K. PANDA

Ubs Business Solutions (India) Private Limited (Successor to Credit Suisse Services (India) Pvt Ltd), Pune vs. PCIT, Pune - 1, Pune, Maharashtra

In the result, appeal of the Assessee is allowed

ITA 1407/PUN/2025[2020-21]Status: DisposedITAT Pune28 Nov 2025AY 2020-21

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1407/Pun/2025 निर्धारण वषा / Assessment Year: 2020-21 Ubs Business Solutions (India) V The Principal Pvt. Ltd. (Successor To Credit S. Commissioner Of Suisse Services (India) Pvt Income Tax, Ltd.), Pune-1. Cluster A, Eon Free Zone, Plot No.1, S.No.77, Ground To 5Th Floors In Wing 1, 3Rd To 5Th Floor In Wing 2, Kharadi Midc Knowledge Park, Pune – 411014. Pan: Aabcu8718M Appellant/ Assessee Respondent / Revenue Assessee By Shri Rajendra Agiwal - Ar Revenue By Shri Amit Bobde – Cit(Dr) Date Of Hearing 23/09/2025 Date Of Pronouncement 28/11/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed By The Assessee Against The Order Of Ld.Principal Commissioner Of Income Tax, Pune-1 Passed Under Section 263 Of The Income Tax Act, 1961 For A.Y.2020-21, Dated 31.03.2025 Emanating From Assessment Order U/S.143(3) R.W.S 144B

Section 143(3)Section 144BSection 263Section 80G

reasons for selection of scrutiny under CASS (a) Erred in assumption of jurisdiction U/s 263 to revise the assessment order issued under section 143(3) read with section 144B of the Act, on the issue which was beyond the scope of reasons for scrutiny as per CASS. 2.2. Selection