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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 Milestone Aviation Asset Holding Group No.25 Ltd., Ireland vs. ACIT Int. Tax. Circle 3(1)(1) New Delhi, New Delhi

In the result, this issue is decided in favour of the appellant assessees and against the Revenue

ITA 1351/DEL/2025[2022-2023]Status: DisposedITAT Delhi31 Oct 2025AY 2022-2023

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita No.1350/Del./2025, A.Y. 2022-23 Vertical Aviation No. 1 Ltd., Assistant Commissioner Of Dolmen House, 3Rd Floor, Income Tax, 4 Earlsfort Terrace, Vs. Circle Int. Tax. - 3(1)(1), Dublin 2, Ireland Do2E024 Civic Centre, Minto Road, Pan: Aafcv8726N New Delhi-110002 (Appellant) (Respondent) Ita No.1351/Del./2025, A.Y. 2022-23 The Milestone Aviation Assistant Commissioner Of Asset Holding Group No. 25 Income Tax, Ltd., Vs. Circle Int. Tax. - 3(1)(1), Dolmen House, 3Rd Floor, Civic Centre, Minto Road, 4 Earlsfort Terrace, New Delhi-10002 Dublin 2, Ireland D02E024 Pan: Aahct8009N (Appellant) (Respondent) Both Appellant By Sh. Sachit Jolly, Sr. Advocate Ms. Rashi Khanna, Advocate Ms. Viyushti Rawat, Advocate (Vc) Sh. Devansh Jain, Advocate Ms. Disha Jham, Advocate Sh. Soham Dua, Advocate, Sh. Hardeep Singh, Advocate & Sh. A. S. Bajpai, Advocate Both Respondent By Shri Indruj S. Rai, Spl. Counsel, Sh. Sanjeev Menon, Jr. Sc, Sh. Rahul Singh, Jr. Sc, Sh. Gaurav Kumar, Adv. Ms. Rini Handa, Jcit (Intl. Tax) Date Of Hearing 12/09/2025 Date Of Pronouncement 31/10/2025 Common & Identical.

Section 143(3)Section 153Section 194LSection 9(1)(vii)

identical. 2. Both appeals of the assessee for Assessment Year (‘AY’) 2022-23 are filed against separate order dated 30.01.2025 passed under section 143(3)/144C(13) of the of the Income Tax Act, 1961 (‘Act’) by the Assistant Commissioner of Income Tax, Circle International Tax-3(1)(1), Delhi

Vertical Aviation No. 1 Limited, Ireland vs. ACIT Int. Tax. Circle 3(1)(1) New Delhi, New Delhi

In the result, this issue is decided in favour of the appellant assessees and against the Revenue

ITA 1350/DEL/2025[2022-2023]Status: DisposedITAT Delhi31 Oct 2025AY 2022-2023

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraita No.1350/Del./2025, A.Y. 2022-23 Vertical Aviation No. 1 Ltd., Assistant Commissioner Of Dolmen House, 3Rd Floor, Income Tax, 4 Earlsfort Terrace, Vs. Circle Int. Tax. - 3(1)(1), Dublin 2, Ireland Do2E024 Civic Centre, Minto Road, Pan: Aafcv8726N New Delhi-110002 (Appellant) (Respondent) Ita No.1351/Del./2025, A.Y. 2022-23 The Milestone Aviation Assistant Commissioner Of Asset Holding Group No. 25 Income Tax, Ltd., Vs. Circle Int. Tax. - 3(1)(1), Dolmen House, 3Rd Floor, Civic Centre, Minto Road, 4 Earlsfort Terrace, New Delhi-10002 Dublin 2, Ireland D02E024 Pan: Aahct8009N (Appellant) (Respondent) Both Appellant By Sh. Sachit Jolly, Sr. Advocate Ms. Rashi Khanna, Advocate Ms. Viyushti Rawat, Advocate (Vc) Sh. Devansh Jain, Advocate Ms. Disha Jham, Advocate Sh. Soham Dua, Advocate, Sh. Hardeep Singh, Advocate & Sh. A. S. Bajpai, Advocate Both Respondent By Shri Indruj S. Rai, Spl. Counsel, Sh. Sanjeev Menon, Jr. Sc, Sh. Rahul Singh, Jr. Sc, Sh. Gaurav Kumar, Adv. Ms. Rini Handa, Jcit (Intl. Tax) Date Of Hearing 12/09/2025 Date Of Pronouncement 31/10/2025 Common & Identical.

Section 143(3)Section 153Section 194LSection 9(1)(vii)

identical. 2. Both appeals of the assessee for Assessment Year (‘AY’) 2022-23 are filed against separate order dated 30.01.2025 passed under section 143(3)/144C(13) of the of the Income Tax Act, 1961 (‘Act’) by the Assistant Commissioner of Income Tax, Circle International Tax-3(1)(1), Delhi