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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)

Rajeev Ranjan, Patna Bihar vs. Asstt. Commissioner of Income Tax, Patna, Bihar

The appeal of the assessee is allowed for statistical purposes

ITA 150/PAT/2025[2017-2018]Status: DisposedITAT Patna21 Oct 2025AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.150/Pat/2025 Assessment Year: 2017-18 Rajeev Ranjan..…………………..………. …………………....Appellant Saket Puri New Kunj Colony, Bazar Samiti, Patna, Bihar- 800016.. [Pan: Alfpr5222F] Vs. Acit, Patna………..…....…..……………..………………….…..... Respondent Appearances By: Shri Tripurari Kumar, Ca, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 14, 2025 Date Of Pronouncing The Order : October 21, 2025 आदेश / Order Per Sonjoy Sarma: This Appeal Is Directed By The Assessee Against The Order Dated 23.01.2025 Passed By The Cit(Appeals), Under Section 250 Of The Income-Tax Act, 1961. 2. Brief Facts Of The Case Are That The Assessing Officer Completed The Assessment Under Section 143(3) Of The Income-Tax Act, 1961, Determining The Total Income Of The Assessee At ₹1,46,89,000 As Against The Income Of ₹99,90,000 Declared In The Return Of Income. The Assessing Officer Made An Addition Of ₹46,99,000 Under Section 69A Of The Act, Treating It As Unexplained Cash Deposits.

Section 143(3)Section 250Section 69A

section 250 of the Income-tax Act, 1961. 2. Brief facts of the case are that the Assessing Officer completed the assessment under Section 143(3) of the Income-tax Act, 1961, determining the total income of the assessee at ₹1,46,89,000 as against the income

Pankaj Kumar, Muzaffarpur vs. Commissioner of Income Tax, Patna

In the result, all the four appeals of the assessee are allowed for statistical purposes

ITA 650/PAT/2024[2020-21]Status: DisposedITAT Patna21 Oct 2025AY 2020-21

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.649, 645, 646 & 650/Pat/2024 Assessment Years: 2017–18, 2018–19, 2019–20 & 2020–21 Pankaj Kumar……..……………..………. …………………....Appellant Saraiyaganj, Muzaffarpur, Bihar-842001.. [Pan: Alipk3534A] Vs. Cit Patna……………......…..……………..………………….…..... Respondent Appearances By: Shri Amit Kamalia, Ca., Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : October 21, 2025 आदेश / Order Per Sonjoy Sarma: These Four Captioned Appeals—Ita No. 649/Patna/2024 For A.Y. 2017–18, Ita No. 645/Patna/2024 For A.Y. 2018–19, Ita No. 646/Patna/2024 For A.Y. 2019–20 & Ita No. 650/Patna/2024 For A.Y. 2020–21—Are Filed By The Same Assessee Against The Orders Of The Learned Cit(A), Relating To Penalty Imposed Under Section 270A Of The Income-Tax Act, 1961, Arising Out Of The Respective Assessment Orders. Since The Issues Involved In All These Appeals Are Common Except For Variation In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noticed That There Is A Delay Of Four Days In Filing The Appeals Before The Tribunal. The Assessee Has Filed A Petition

Section 132Section 143(3)Section 153ASection 270A

However, in the original return filed earlier, the assessee had declared an income of ₹4,17,550. The assessment was completed under Section 143(3) read with Section 153A of the Act determining total income at ₹5,87,550, thereby accepting the additional income offered by the assessee during

Pankaj Kumar, Muzaffarpur vs. Comissioner of Income Tax, Patna

In the result, all the four appeals of the assessee are allowed for statistical purposes

ITA 649/PAT/2024[2017-18]Status: DisposedITAT Patna21 Oct 2025AY 2017-18

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.649, 645, 646 & 650/Pat/2024 Assessment Years: 2017–18, 2018–19, 2019–20 & 2020–21 Pankaj Kumar……..……………..………. …………………....Appellant Saraiyaganj, Muzaffarpur, Bihar-842001.. [Pan: Alipk3534A] Vs. Cit Patna……………......…..……………..………………….…..... Respondent Appearances By: Shri Amit Kamalia, Ca., Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : October 21, 2025 आदेश / Order Per Sonjoy Sarma: These Four Captioned Appeals—Ita No. 649/Patna/2024 For A.Y. 2017–18, Ita No. 645/Patna/2024 For A.Y. 2018–19, Ita No. 646/Patna/2024 For A.Y. 2019–20 & Ita No. 650/Patna/2024 For A.Y. 2020–21—Are Filed By The Same Assessee Against The Orders Of The Learned Cit(A), Relating To Penalty Imposed Under Section 270A Of The Income-Tax Act, 1961, Arising Out Of The Respective Assessment Orders. Since The Issues Involved In All These Appeals Are Common Except For Variation In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noticed That There Is A Delay Of Four Days In Filing The Appeals Before The Tribunal. The Assessee Has Filed A Petition

Section 132Section 143(3)Section 153ASection 270A

However, in the original return filed earlier, the assessee had declared an income of ₹4,17,550. The assessment was completed under Section 143(3) read with Section 153A of the Act determining total income at ₹5,87,550, thereby accepting the additional income offered by the assessee during

Pankaj Kumar, Muzaffarpur vs. Commissioner of Income Tax, Patna

In the result, all the four appeals of the assessee are allowed for statistical purposes

ITA 646/PAT/2024[2019-20]Status: DisposedITAT Patna21 Oct 2025AY 2019-20

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishraι.Τ.Α. Nos.649, 645, 646 & 650/Pat/2024

Section 132Section 143(3)Section 153ASection 270A

However, in the original return filed earlier, the assessee had declared an income of ₹4,17,550. The assessment was completed under Section 143(3) read with Section 153A of the Act determining total income at ₹5,87,550, thereby accepting the additional income offered by the assessee during

Pankaj Kumar, Muzaffarpur vs. Commissioner of Income Tax, Patna

In the result, all the four appeals of the assessee are allowed for statistical purposes

ITA 645/PAT/2024[2018-19]Status: DisposedITAT Patna21 Oct 2025AY 2018-19

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. Nos.649, 645, 646 & 650/Pat/2024 Assessment Years: 2017–18, 2018–19, 2019–20 & 2020–21 Pankaj Kumar……..……………..………. …………………....Appellant Saraiyaganj, Muzaffarpur, Bihar-842001.. [Pan: Alipk3534A] Vs. Cit Patna……………......…..……………..………………….…..... Respondent Appearances By: Shri Amit Kamalia, Ca., Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : October 21, 2025 आदेश / Order Per Sonjoy Sarma: These Four Captioned Appeals—Ita No. 649/Patna/2024 For A.Y. 2017–18, Ita No. 645/Patna/2024 For A.Y. 2018–19, Ita No. 646/Patna/2024 For A.Y. 2019–20 & Ita No. 650/Patna/2024 For A.Y. 2020–21—Are Filed By The Same Assessee Against The Orders Of The Learned Cit(A), Relating To Penalty Imposed Under Section 270A Of The Income-Tax Act, 1961, Arising Out Of The Respective Assessment Orders. Since The Issues Involved In All These Appeals Are Common Except For Variation In Figures & Assessment Years, They Were Heard Together & Are Being Disposed Of By This Common Order For The Sake Of Convenience. 2. At The Outset, It Is Noticed That There Is A Delay Of Four Days In Filing The Appeals Before The Tribunal. The Assessee Has Filed A Petition

Section 132Section 143(3)Section 153ASection 270A

However, in the original return filed earlier, the assessee had declared an income of ₹4,17,550. The assessment was completed under Section 143(3) read with Section 153A of the Act determining total income at ₹5,87,550, thereby accepting the additional income offered by the assessee during

Dinesh Kumar Singhania, Kolkata vs. I.T.O., Ward - 34(1), Kolkata

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

ITA 1151/KOL/2025[2016-2017]Status: DisposedITAT Kolkata21 Oct 2025AY 2016-2017

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 250Section 44ASection 68Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘SMC’ BENCH, KOLKATA Before SHRI SONJOY SARMA, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT

M/S Rarity Agencies Limited, Kolkata vs. ITO, Ward 9(1), Kolkata

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

ITA 2341/KOL/2024[2015-16]Status: DisposedITAT Kolkata21 Oct 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 10(38)Section 143(3)Section 250Section 68

आयकर अपीलीय अधिकरण कोलकाता 'एसएमसी' पीठ, कोलकाता में IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘SMC’ BENCH, KOLKATA श्री संजय

M/S. Enfield Vyapaar Pvt. Ltd., Kolkata vs. I.T.O., Ward - 1(1), Kolkata

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

ITA 142/KOL/2023[2008-2009]Status: DisposedITAT Kolkata21 Oct 2025AY 2008-2009

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 144Section 147Section 148Section 250Section 263Section 282Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘B’ BENCH, KOLKATA Before SHRI SONJOY SARMA, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT

Balachandra Builders Pvt. Ltd., Chennai vs. DCIT, Corp. Circle-1(2), Chennai

In the result, appeal of the assessee is allowed

ITA 989/CHNY/2025[2010-11]Status: DisposedITAT Chennai21 Oct 2025AY 2010-11

Bench: Shri Manu Kumar Giri & Shri S.R. Raghunathaआयकर अपील सं./Ita No.: 989/Chny/2025 िनधा"रण वष"/Assessment Year : 2010-11 V. Balchandra Builders Private Limited, Deputy Commissioner Of No.10 Venkataratnam Nagar, Adyar, Income Tax, Chennai- 600 020. Corporate Circle 1(2), Chennai. [Pan: Aaacb6727A] (अपीलाथ"/Appellant) (""यथ"/Respondent) : अपीलाथ" क" ओर से/ Appellant By Mr.N.Arjun Raj, Advocate, : ""यथ" क" ओर से /Respondent By Ms.R.Anitha, Addl.Cit : सुनवाई क" तार"ख/Date Of Hearing 28.07.2025 : घोषणा क" तार"ख /Date Of Pronouncement 21.10.2025

Section 143(2)Section 143(3)Section 147Section 148Section 80I

into his possession after the original assessment. The reasons merely rely on interpretation of facts already disclosed and examined in the assessment under section 143(3). Hence, the reopening lacks the jurisdictional foundation. As the reopening itself is held to be invalid, we are not inclined to go into ... assessment under section 147 is bad in law and without Balachandra Builders Pvt Ltd :: 9 :: jurisdiction. Consequently, the reassessment order passed under section 143(3) r.w.s. 147 dated 19.01.2016 is quashed. 11. In the result, appeal of the assessee is allowed. Order pronounced on the 21st day of October

Parasuraman, Cuddalore vs. Assessing Officer, Cuddalore

In the result, the appeal of the assessee is allowed

ITA 2093/CHNY/2025[2022-23]Status: DisposedITAT Chennai21 Oct 2025AY 2022-23

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकरअपीलसं./Ita No.:2093/Chny/2025 यनिाारणवर्ा / Assessment Year:2022-23 Parasuraman, Income Tax Officer, No.155/2, Middle Street, Vs. Ward-2, Kadampuliyur & Post, Cuddalore. Panruti Taluk, Cuddalore, Tamil Nadu-607 103. [Pan:Clqpp6548F] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे/Appellant By : None प्रत्यर्थीकीओरसे/Revenue By : Mr.C.P.Solomon, Jcit सुनवाईकीतारीख/Date Of Hearing : 21.10.2025 घोर्णाकीतारीख/Date Of Pronouncement: 21.10.2025 आदेश /O R D E R Per M. Balaganesh, Am : This Appeal By The Assessee Is Filed Against The Order Of The Learned Commissioner Of Income Tax (Appeal), Nfac, Delhi, (In Short Ld.Cit(A) For The Assessment Year 2022-23, Vide Order Dated 23.06.2025. 2.0 The Only Issue To Be Decided In This Appeal Is As To Whether The Ld.Cit(A) Was Justified In Confirming The Levy Of Penalty U/S 271B Of The Act In The Facts & Circumstances Of The Instant Case.

For Appellant: NoneFor Respondent: Mr.C.P.Solomon, JCIT
Section 143(3)Section 271BSection 44A

आयकर अपीलीय अधिकरण,’सी’ न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI श्रीएम.बालगणेश, लेखासदस्यकेसमक्षएवं. श्रीएसएसववश्वनेत्ररवव, न्याययकसदस्य

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Tiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1655/CHNY/2025[2021-22]Status: DisposedITAT Chennai21 Oct 2025AY 2021-22

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

serent arttehre ara, ‘al’ saa, Ueas IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI AN sist atrot &, Soar Ue

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Thiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1654/CHNY/2025[2020-21]Status: DisposedITAT Chennai21 Oct 2025AY 2020-21

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

serent arttehre ara, ‘al’ saa, Ueas IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI AN sist atrot &, Soar Ue

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Thiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1653/CHNY/2025[2019-20]Status: DisposedITAT Chennai21 Oct 2025AY 2019-20

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

serent arttehre ara, ‘al’ saa, Ueas IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI AN sist atrot &, Soar Ue

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Tiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1652/CHNY/2025[2018-19]Status: DisposedITAT Chennai21 Oct 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

serent arttehre ara, ‘al’ saa, Ueas IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI AN sist atrot &, Soar Ue

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Tiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1651/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Oct 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

serent arttehre ara, ‘al’ saa, Ueas IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI AN sist atrot &, Soar Ue

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Chennai

In the result, all the six appeals of the Revenue are

ITA 1650/CHNY/2025[2015-16]Status: DisposedITAT Chennai21 Oct 2025AY 2015-16

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

serent arttehre ara, ‘al’ saa, Ueas IN THE INCOME TAX APPELLATE TRIBUNAL ‘B’ BENCH, CHENNAI AN sist atrot &, Soar Ue

M/S. Primary Agriculture Credit Co-Op Society, Chikkamagaluru vs. Income Tax Officer, Ward-1, Chikmagalur

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

ITA 1826/BANG/2025[2020-21]Status: DisposedITAT Bangalore21 Oct 2025AY 2020-21

Bench: Shri Prashant Maharishiassessment Year : 2020-21

For Appellant: Shri Siddesh Nagaraj Gaddi, CAFor Respondent: Shri Ganesh R. Ghale, Advocate, Standing Counsel
Section 143(2)Section 143(3)Section 154Section 37Section 80PSection 80P(2)(a)

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH : BANGALORE BEFORE SHRI PRASHANT MAHARISHI, VICE PRESIDENT Assessment year : 2020-21 M/s

Hewlett Packard Financial Services (India) P. Ltd, Bangalore vs. Asst CIT Cir 2(1)(2), Bangaluru

Accordingly, the ground is dismissed as not pressed

ITA 915/MUM/2017[2011-12]Status: DisposedITAT Mumbai21 Oct 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am

Section 115JSection 143(3)Section 250Section 41

IN THE INCOME TAX APPELLATE TRIBUNAL “H” BENCH, MUMBAI BEFORE SMT BEENA PILLAI, JM & MS PADMAVATHY S, AM I.T.A. No

M/S Sushila Devi Centre for Professional Studies and Research, Dehradun vs. PCIT (Central), Kanpur (Jao- Dy. Commissioner of Income Tax, Central Circle, Dehradun)

ITA 131/DDN/2025[2024-25]Status: DisposedITAT Dehradun17 Oct 2025AY 2024-25

Bench: Shri Yogesh Kumar U.S. & Shri Manish Agarwal

Section 12Section 127Section 127(2)(a)Section 12ASection 132Section 143(3)

PCIT is based on mere surmises and conjectures. 3. That the reference made by the Assessing Officer under the second proviso to Section 143(3) read with Section 12AB(4)(b) is illegal, without jurisdiction, and contrary to the mandate of the Act. The impugned order is liable ... above, the order passed by PCIT Central, on the basis of reference made by AO under the second proviso to the provisions of section 143(3) of the Act is void ab initio and bad in law, as no satisfaction note has been prepared by the AO before making

Ardent Steels Pvt. Ltd., Raipur vs. Pr. Commissioner of Income Tax, Raipur-1, Raipur

The appeal of the assessee is allowed in terms of our aforesaid observations

ITA 337/RPR/2025[2020-21]Status: DisposedITAT Raipur17 Oct 2025AY 2020-21

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 337/Rpr/2025 (िनधा"रण वष"Assessment Year: 2020-21)

For Appellant: Shri R. B. Doshi, CAFor Respondent: Shri S. L. Anuragi, CIT-DR
Section 143(3)Section 263

आयकर अपीलीय अिधकरण, रायपुर "ायपीठ, रायपुर IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH, RAIPUR "ी पाथ" सारथी चौधर", "ाियक सद