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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)

Enlarge Buldcon LLP, Rajkot vs. DCIT, CC-1, Rajkot

ITA 623/RJT/2024[2020-21]Status: DisposedITAT Rajkot26 Feb 2026AY 2020-21

Bench: Dr. Arjun Lal Saini & Dr. Dinesh Mohan Sinha

For Appellant: Shri Mehul Ranpura, ld.ARFor Respondent: Shri Sanjay Punglia, Ld.CIT-DR
Section 143(3)Section 147Section 148Section 250Section 69C

आयकर अपील"य अ"धकरण, राजकोट "यायपीठ, राजकोट। IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE DR. ARJUN

Assistant Commissioner of Income Tax, Central Circle-2, Patna vs. Patna Iron Pvt. Ltd., Patna

In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed

ITA 373/PAT/2025[2020-21]Status: DisposedITAT Patna26 Feb 2026AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Appellant) (Respondent) Pan No. Aafcp2484B Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Respondent) (Appellant) Sushil Kumar Kanodia N-601, Profesor Colony, Acit, Central Circle-2 Chitragupta Nagar, Kanakrbagh, Vs. Patna, Bihar Patna-800020, Bihar (Appellant) (Respondent) Pan No. Agypk0702D Assessee By : Shri Manish Rastogi, Ar Revenue By : Md. A.H. Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 26.02.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C

period of six years and the assessment ought to have been completed under section 153C of the Act and the assessment completed under section 143(3) of the Act ought to have been quashed. 5.1. The ld. AR submitted that once the material has been seized during the course

Patna Iron Pvt. Ltd., Patna vs. ACIT, Central Circle-2, Patna

In the result, the appeals of the assessee are allowed and appeal of

ITA 332/PAT/2025[2020-21]Status: DisposedITAT Patna26 Feb 2026AY 2020-21

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C

period of six years and the assessment ought to have been completed under section 153C of the Act and the assessment completed under section 143(3) of the Act ought to have been quashed. 5.1. The Id. AR submitted that once the material has been seized during the course

Sushil Kumar Kanodia, Patna vs. ACIT, Central Circle-2, Patna

In the result, the appeals of the assessee are allowed and appeal of the Revenue is dismissed

ITA 237/PAT/2025[2017-18]Status: DisposedITAT Patna26 Feb 2026AY 2017-18

Bench: Shri Duvvuru Rl Reddy, Vp & Shri Rajesh Kumar, Am Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Appellant) (Respondent) Pan No. Aafcp2484B Asst. Commissioner Of Income Patna Iron Pvt. Ltd. Tax, Central Circle-2 Ground Floor, Suprabhat 6Th Floor, Annexe, Central Building, Ceat Compound, Vs. Building, Beer Chand Patel Path, Phulwari, Patna-800001, Bihar Patna, Bihar-800001, (Respondent) (Appellant) Sushil Kumar Kanodia N-601, Profesor Colony, Acit, Central Circle-2 Chitragupta Nagar, Kanakrbagh, Vs. Patna, Bihar Patna-800020, Bihar (Appellant) (Respondent) Pan No. Agypk0702D Assessee By : Shri Manish Rastogi, Ar Revenue By : Md. A.H. Chowdhary, Dr Date Of Hearing: 27.11.2025 Date Of Pronouncement: 26.02.2025

For Appellant: Shri Manish Rastogi, ARFor Respondent: Md. A.H. Chowdhary, DR
Section 132Section 143(2)Section 143(3)Section 153ASection 153C

period of six years and the assessment ought to have been completed under section 153C of the Act and the assessment completed under section 143(3) of the Act ought to have been quashed. 5.1. The ld. AR submitted that once the material has been seized during the course

Anant Kumar, Barabanki vs. Income Tax Officer, Barabanki

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

ITA 499/LKW/2025[2017-18]Status: DisposedITAT Lucknow26 Feb 2026AY 2017-18

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: NoneFor Respondent: Sh. R.R.N. Shukla, Addl CIT DR
Section 115BSection 143(3)Section 250Section 68

wherein the ld. CIT(A) had dismissed the appeals of the assessee against the orders of the ld. Assessing Officer passed under section 143(3) of the Act for the A.Y. 2017-18 on 30.12.2019. The grounds of appeal are as under:- “1. On the facts and circumstances ... declaring a total income of Rs. 10,48,410/-. The case was selected for scrutiny and an assessment was completed under section 143(3) of the Income Tax Act by making an addition of Rs. 73,54,173/- of which additions under section 68 were made of Rs.72

Ram Nath Jaiswal, Faizabad vs. Commissioner of Income-Tax (Appeals), Lucknow

In the result, the appeal of the assessee is allowed for statistical purposes while the Stay application is held to be allowed

ITA 13/LKW/2024[2018-19]Status: DisposedITAT Lucknow26 Feb 2026AY 2018-19

Bench: SH. SUDHANSHU SRIVASTAVA, JUDICIAL MEMBER AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Akash Agrawal, C.AFor Respondent: Sh. R.R.N. Shukla, Addl CIT DR
Section 143(3)Section 250Section 69A

wherein the ld. CIT(A) has dismissed the appeal of the assessee against the orders of the National e-Assessment Centre passed under section 143(3) of the Income Tax Act on 7.04.2021 in respect of the A.Y. 2018-19 and a stay application filed for stay of balance demand

Joint Commisioner of Income Tax(OSD) Circle 3(1)(1) Ahmedabad, Ahmedabad vs. Nirma Chemical Works Private Limited, Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 164/AHD/2026[2020-21]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2020-21

Bench: Dr. B.R.R. Kumar, Vice-Shri T.R. Senthil Kumar

Section 143(3)Section 14ASection 250

insertion of Explanation to Section 14A and amendment of Rule 8D w.e.f. 02/06/2016.” 3. In this case, the Assessing Officer completed assessment under section 143(3) r.w.s. 144B on 16.09.2022 and made disallowance under section 14A of Rs. 7,50,65,938/-, observing that the assessee had investments

Adani Infrastructure Management Services Limited, Ahmedabad vs. Nafac Delhi, Present Jurisdiction Deputy Commissioner of Income Tax, Circle 1(1)(1), Ahmedabad

In the result, the appeal of the assessee stands allowed

ITA 300/AHD/2025[2021-22]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2021-22

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokar

For Appellant: Shri Vartik Chokshi, ARFor Respondent: Shri Santosh Kumar, Sr.DR
Section 143(3)Section 234ASection 250Section 40A(2)(b)

आयकर अपीलीय अिधकरण, अहमदाबाद "ायपीठ “ए“,अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD ["ी संजय गग", "ाियक सद

Manubhai Shamrav Kharat, Ahmedabad vs. ITO, Ward 1(2)(3), Ahmedabad

In the result, the appeal of the assessee is dismissed

ITA 2674/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2022-23

Bench: Ms. Suchitra Kambleassessment Year 2022-23

For Appellant: Shri P D Shah, A.R. &For Respondent: Shri Suresh Chand Meena, Sr. D.R
Section 143(3)Section 144BSection 271BSection 44A

THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “SMC” BENCH, AHMEDABAD Before Ms. Suchitra Kamble, Judicial Member Assessment Year 2022-23 Manubhai

Rachna Dipesh Laddha, Vadodara vs. Income Tax Officer, Ward 1(3)(2) Vadodara Gujarat, Vadodara

In the result, the appeal of the assessee is dismissed

ITA 1922/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2017-18

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: NoneFor Respondent: Shri Rignesh Das, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 69A

unexplained credit, and accordingly completed the Rachna Dipesh Laddha vs. ITO Asst.Year –2017-18 - 3– assessment under section 143(3) of the Act assessing the total income at Rs. 5,50,87,040/-. 5. Aggrieved by the assessment order, the assessee preferred an appeal before the Commissioner of Income

Incometax Officer, Ward-5(3)(2), Ahmedabad vs. Tanmai Raj Gopal, Ahmedabad

ITA 1887/AHD/2025[2022-23]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2022-23

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Respondent byFor Respondent: Shri Rignesh Das, CIT-DR
Section 234DSection 250Section 6(1)(a)

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, AHMEDABAD BEFORE SMT. ANNAPURNA GUPTA, ACCOUNTANT MEMBER & SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER

Concord Biotech Ltd., Ahmedabad vs. The Dy.CIT, Circle-1(1)(1), Ahmedabad

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

ITA 1744/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2016-17

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Ms. Kinjal Shah, ARFor Respondent: Smt. Urvashi Mandhan, Sr. DR
Section 133(6)Section 143(3)Section 147Section 148

income for Assessment Year 2016–17 on 17.10.2016 declaring total income of Rs. 114,93,76,740/-. The assessment was originally completed under section 143(3) of the Act on 27.11.2018 assessing the total income at Rs. 1,15,17,83,428/- under normal provisions. Subsequently, on the basis

Parul Tulsidas Mistry, Vadodara vs. The ITO, Ward-1(2)(4), Vadodara

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

ITA 1280/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.1280/Ahd/2025 िनधा"रण वष" /Assessment Year : 2017-18 Parul Tulsidas Mistry The Ito बनाम/ 21, Paradise Complex Ward-1(2)(4) V/S. Sayajigunj Vadodara – 390 007 Vadodara – 390 005 (Gujarat) "थायी लेखा सं./Pan: Aaspm 5799 G (अपीलाथ$/ Appellant) (%& यथ$/ Respondent) Assessee By : Shri Hardik Vora, Ar Revenue By : Shri Santosh Kumar, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 02/12/2025 घोषणा की तारीख /Date Of Pronouncement: 26/02/2026 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 06/09/2023 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2017-2018. 2. The Assessee, In This Appeal, Has Raised The Following Grounds Of Appeal: Parul Tulsidas Mistry Vs. Ito Asst.Year: 2017-18

For Appellant: Shri Hardik Vora, ARFor Respondent: Shri Santosh Kumar, Sr.DR
Section 143(3)Section 250

state that, Parul Tulsidas Mistry vs. ITO Asst.Year: 2017-18 3 1. I have filed an appeal against the assessment order passed under section 143(3) of the Income Tax Act, 1961 by the Ld. Income Tax Officer, Ward 1(2)(4), Vadodara

Bhavani Ceramics Pvt Ltd, Mehsana vs. ACIT, Mehsana Circle, Mehsana

In the result, the appeal of the assessee is allowed

ITA 977/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad26 Feb 2026AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaassessment Year 2012-13

For Appellant: Shri Bandish Soparkar, A.RFor Respondent: Shri Rameshwar P Meena, Sr. D.R
Section 143Section 143(3)Section 147Section 148

THE INCOME TAX APPELLATE TRIBUNAL AHMEDABAD “D” BENCH Before Ms. Suchitra Kamble, Judicial Member And Shri Narendra Prasad Sinha, Accountant

Venkata Ramana Murthy Bollapragada, Hyderabad vs. ITO, Ward-13(1), Hyderabad

In the result, the appeal of the assessee is allowed in terms of our aforesaid observations

ITA 1961/HYD/2025[2016-17]Status: DisposedITAT Hyderabad26 Feb 2026AY 2016-17

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1961/Hyd/2025 (िनधा"रण वष"/Assessment Year:2016-17) Venkata Ramana Murthy Vs. Income Tax Officer, Bollapragada, Ward-13(1), Hyderabad. Hyderabad. Pan: Abmpb7770R (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri H. Srinivasulu, Advocate राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 24/02/2026 घोषणा की तारीख/Date Of 26/02/2026 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 27/10/2025, Which In Turn Arises From The Order Passed By The Additional/Joint Commissioner Of Income Tax, Range-13, Hyderabad Under Section 271D Of The Income Tax Act, 1961 (For Short, “The Act”), Dated 30/06/2022 For The Assessment Year

For Appellant: Shri H. SrinivasuluFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 143(3)Section 269SSection 271DSection 274Section 54F

scrutiny” under CASS for examining the cash deposits made in his bank account. 3. Thereafter, the AO vide his order passed under section 143(3) of the Act, dated 25/10/2018 after making necessary verifications had accepted the returned income of the assessee as such. 4. The Additional/Joint Commissioner of Income ... 12/11/2015: Rs.8 lakhs; AND (II) that the AO while framing the assessment in the case of the assessee vide his order under section 143(3) of the Act, dated 25/10/2018 had not recorded any satisfaction for initiating penalty proceedings under section 271D of the Act. Elaborating on his contentions

Ramdev Munadhda, Warangal vs. Income Tax Office Ward -1, Warangal

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

ITA 1837/HYD/2025[2017-2018]Status: DisposedITAT Hyderabad26 Feb 2026AY 2017-2018
Section 143(3)Section 147Section 148Section 148ASection 149(1)(b)

from the end of the relevant assessment year, Page 10 of APB. Thereafter, the AO framed the assessment vide his order passed under Section 143(3) r.w.s. 147 r.w.s. 144B, determining the total income of the assessee at Rs. 8,53,659/-. Aggrieved, the assessee assailed the assessment order before

Virchow Petrochemical Private Limited, Hyderabad vs. ACIT., Central Circle-8(1), Hyderabad

ITA 1191/HYD/2025[2015-16]Status: DisposedITAT Hyderabad26 Feb 2026AY 2015-16
For Appellant: Shri M.V. Prasad, CAFor Respondent: Ms. U. Mini Chandran
Section 143(3)Section 147Section 148Section 250

30/11/2015 declaring an income of Rs. 109,21,94,530/-. 3. The AO had vide his order passed under section 143(3) of the Act, dated 11/12/2018, framed the original assessment in the case of the assessee company, wherein its returned income was accepted as such. 4. Thereafter, the concluded ... assessee company, which is engaged in the business of manufacturing of pharmaceuticals, was originally assessed by the AO vide his order passed under section 143(3) of the Act, dated 11/12/2018, wherein, after exhaustive deliberations, its returned income was accepted as such, Page Nos.116 to 121 of APB. Elaborating further

M/S. Lupin Vinimay Pvt. Ltd., Kolkata vs. I.T.O., Ward - 9(3), Kolkata

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

ITA 3103/KOL/2025[2010-2011]Status: DisposedITAT Kolkata26 Feb 2026AY 2010-2011

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(3)Section 147Section 148Section 250Section 68

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

Jindal Commodities, Kolkata vs. ITO, Ward 43(2), Kolkata

In the result, the present appeal is dismissed

ITA 2905/KOL/2025[2012-2013]Status: DisposedITAT Kolkata26 Feb 2026AY 2012-2013

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(2)Section 143(3)Section 147Section 148Section 151Section 234ASection 249(2)Section 249(3)Section 250Section 5

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

Jermels Accademy, Darjeeling vs. ITO, Ward 2(2), Exemp, Siliguri

ITA 2750/KOL/2025[2017-2018]Status: DisposedITAT Kolkata26 Feb 2026AY 2017-2018

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 10Section 11Section 12ASection 12A(1)(ac)Section 12A(1)(ba)Section 12A(2)Section 139Section 144Section 2(15)Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATΑ ‘Β' ΒENCH AT KOLKATA Before SHRI SONJOY SARMA, JUDICIAL MEMBER & SHRI RAKESH MISHRA