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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)

Abdul Salam Shaik, Piler vs. Income Tax Officer, Ward-1(1), Tirupati

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

ITA 1371/HYD/2025[2017-18]Status: DisposedITAT Hyderabad18 Mar 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

Section 142(1)Section 143(2)Section 143(3)Section 250Section 68Section 69

1371/Hyd/2025 Abdul Salam Shaik vs. ITO to the income of the assessee. Accordingly, the assessment was completed by Ld. AO under section 143(3) of the Act on 03.12.2019 determining the total income of the assessee at Rs.1,15,12,680/-. 4. Aggrieved by the order ... subsequently passed an order giving effect to the order of the Ld. CIT(A) under section 250 read with section 143(3) of the Act dated 29.07.2025 whereby an addition of Rs.9,70,000/- has been deleted. Accordingly, the issue that survives for adjudication before the Tribunal relates

Indis Central Park Properities Private Limited, Hyderabad vs. DCIT., Central Circle-3(3), Hyderabad

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

ITA 1180/HYD/2025[2018-19]Status: DisposedITAT Hyderabad18 Mar 2026AY 2018-19

Bench: SHRI VIJAY PAL RAO (Vice President), SHRI MADHUSUDAN SAWDIA (Accountant Member)

before the Ld. CIT(A) for Assessment Year 2018–19 against the assessment order passed by the Learned Assessing Officer (“Ld. AO”) under section 143(3) read with section 143(3A) and section 143(3B) of the Income Tax Act, 1961 (“the Act”) dated 15.04.2021. During the course of appellate

Mayuri Electronics Private Limited, Namakkal vs. DCIT Circle-1, Erode

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

ITA 4051/CHNY/2025[2014-15]Status: DisposedITAT Chennai18 Mar 2026AY 2014-15

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपीलसं./Ita No.4051/Chny/2025 "नधा"रण वष" / Assessment Year: 2014-15 Mayuri Electronics Private Limited, The Deputy Commissioner Of 171/1, Co-Operative Colony, Vs. Income Tax, Mohanur Road, Circle-1, Namakkal – 637 001. Erode. [Pan: Aaicm-3674-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Mr. G. Akash, Advocate ""यथ" क" ओर से /Respondent By : Mr. Aroon Praasad, Addl. Cit सुनवाई क" तार"ख/Date Of Hearing : 25.02.2026 घोषणा क" तार"ख /Date Of Pronouncement : 18.03.2026

For Appellant: Mr. G. Akash, AdvocateFor Respondent: Mr. Aroon Praasad, Addl. CIT
Section 143(3)Section 221Section 250Section 68

आयकर अपील"य अ"धकरण, ‘डी’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘D’ BENCH, CHENNAI "ी जॉज" जॉज

Suraj Vijay Kulkarni, Mumbai vs. ITO 8(1)(3), Mumbai

In the result, the addition is restricted to Rs

ITA 8317/MUM/2025[2010-11]Status: DisposedITAT Mumbai18 Mar 2026AY 2010-11

Bench: SHRI ANIKESH BANERJEE (Judicial Member), SHRI JAGADISH (Accountant Member)

For Appellant: Shri Vimal Punmiya & Mr. Dhaval SalotFor Respondent: Shri S. Anbuselvan (SR AR)
Section 143(3)Section 148Section 250Section 69

emanated from the order of the Ld. Income Tax Officer Ward-8(1)(3), Mumbai (for brevity the ‘’Ld. AO”), order passed under section 143(3) r.w.s. 147 of the Act date of order 21.12.2017. 2 Suraj Vijay Kulkarni 2. The brief facts of the case are that the assessee

Mahesh Vishindas Chandwani, Mumbai vs. Dy CIT, Circle 29(2), Mumbai

In the result the Ground No

ITA 6777/MUM/2025[2013-14]Status: DisposedITAT Mumbai18 Mar 2026AY 2013-14

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

For Appellant: Ms. Neha Paranjpe, AdvFor Respondent: Shri Swapnil Choudhary (Sr. DR)
Section 143(2)Section 143(3)Section 250

from the order of the Ld. Deputy Commissioner of Income Tax Circle 29(2), Mumbai (for brevity the ‘Ld. AO') order passed under section 143(3) of the Act date of order 14.03.2016. 2. The assessee has taken the following grounds: “1. The NFAC erred in passing the order dated ... Returns, and other relevant details. Pursuant to the directions of the Tribunal, the Ld. AO passed a set-aside assessment order under section 143(3) read with section 254 of the Act dated 31.10.2018, which is placed at APB pages 109 to 116. In the said set-aside assessment proceedings

The Bombay Dyeing and Manufacturing Company Limited, Mumbai vs. Income Tax Central Circle 2(1)(1), Mumbai

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

ITA 5274/MUM/2025[2018-19]Status: DisposedITAT Mumbai18 Mar 2026AY 2018-19

Bench: Shri Om Prakash Kant, Jm & Ms. Kavitha Rajagopal, Am

For Appellant: Shri Yogesh Thar, A.RFor Respondent: Shri Leyaqat Ali Aafaqui, Sr. AR
Section 115JSection 143(2)Section 143(3)Section 14ASection 234BSection 250Section 43C

IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI OM PRAKASH KANT, JM AND MS. KAVITHA RAJAGOPAL, AM

Reliance Industrial Infrastructure Limited, Mumbai vs. Principal Commissioner of Income Tax -3, Mubmai

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

ITA 3751/MUM/2025[2020-21]Status: DisposedITAT Mumbai18 Mar 2026AY 2020-21

Bench: Shri Vikram Singh Yadav, Am & Ms. Kavitha Rajagopal, Jm M/S. Reliance Industrial Principal Commissioner Of Income Infrastructure Limited, Tax – 3, 5Th Floor, Nkm International House, Aayakar Bhavan, Vs. 178 Backbay Reclamation Marine Maharshi Karve Road, Lines Mumbai – 400 020 Mumbai – 400 020 Pan:Aaacr7637P (Appellant) : (Respondent)

For Respondent: Shri Umashankar Prasad, CIT-DR
Section 143(2)Section 143(3)Section 14ASection 263Section 37(1)Section 80G

IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, AM AND MS. KAVITHA RAJAGOPAL, JM

M/S. Bank of American, N.A, Mumbai vs. The Jt DIT (I.T)3, Mumbai

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

ITA 4154/MUM/2004[2000-2001]Status: DisposedITAT Mumbai18 Mar 2026AY 2000-2001

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Percy PardiwalaFor Respondent: Shri Krishna Kumar, Sr.DR
Section 10Section 10(15)Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)(viia)Section 37(1)Section 44C

incurred any direct expenditure in earning this income. 5. The Assessing Officer (“AO”), vide order dated 28/03/2003 passed under section 143(3) of the Act, disagreed with the submissions of the assessee and held that the harmonious reading of section 10 of the Act would leave no doubt that what ... whether such expenses are incurred in the state in which the Permanent Establishment is situated or elsewhere. 10. The AO, vide order under section 143(3) of the Act, disagreed with the submissions of the assessee and held that there is no dispute that the deduction for Head Office expenditure

The Dy DIT (I.T) 1(1), Mumbai vs. M/S. Bank of America N.A., Mumbai

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

ITA 4090/MUM/2004[2000-2001]Status: DisposedITAT Mumbai18 Mar 2026AY 2000-2001

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhail

For Appellant: Shri Percy PardiwalaFor Respondent: Shri Krishna Kumar, Sr.DR
Section 10Section 10(15)Section 142(1)Section 143(2)Section 143(3)Section 14ASection 250Section 36(1)(viia)Section 37(1)Section 44C

incurred any direct expenditure in earning this income. 5. The Assessing Officer (“AO”), vide order dated 28/03/2003 passed under section 143(3) of the Act, disagreed with the submissions of the assessee and held that the harmonious reading of section 10 of the Act would leave no doubt that what ... whether such expenses are incurred in the state in which the Permanent Establishment is situated or elsewhere. 10. The AO, vide order under section 143(3) of the Act, disagreed with the submissions of the assessee and held that there is no dispute that the deduction for Head Office expenditure

DCIT Central Circle -28, New Delhi vs. Manoj Kumar Singh, New Delhi

In the result, appeal filed by the assessee is allowed in above terms and the appeal of the Revenue is dismissed

ITA 8069/DEL/2025[2013-14]Status: DisposedITAT Delhi18 Mar 2026AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 132ASection 153DSection 28

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘F’: NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI

Ranbir Singh Godara, Delhi vs. Asstt. Commissioner of Income Tax, Delhi

In the result, the Appeal of the Assessee is partly allowed for statistical purpose

ITA 7279/DEL/2025[2017-18]Status: DisposedITAT Delhi18 Mar 2026AY 2017-18

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalranbir Singh Godara Vs Assistant Commissioner Of 451, Village & Po Bharthal, Dwarka, Income Tax, Circle 44(1), E-2 New Delhi Block Civil Centre, Delhi Pan: Amzps2610R Appellant Respondent Assessee By None Revenue By Sh. Dayainder Singh Sidhu, Cit Dr (Through Vc) Date Of Hearing 17/03/2026 Date Of Pronouncement 18/03/2026 Order Per Yogesh Kumar, U.S. Jm: This Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax (Appeals)-31, Delhi, (‘Ld. Cit(A)’ For Short) Dated 29/07/2025 Pertaining To The Assessment Year 2017-18. 2. None Appeared For The Assessee. Considering The Issue Involved In The Present Appeal We Deem It Fit To Decide The Appeal On Hearing The Ld. Department'S Representative & Perused The Material Available On Record.

Section 143(3)

perused the material available on record. 3. Brief facts of the case are that, an assessment order came to be passed under Section 143(3) of the Income Tax Act, (‘Act’ for short) on 30/12/2018 by computing the income of the Assessee at Rs. 3,18,28,559/-, by making

Manoj Kumar Singh, Delhi vs. DCIT(A) Central Circle-28, Delhi

In the result, appeal filed by the assessee is allowed in above terms and the appeal of the Revenue is dismissed

ITA 6383/DEL/2025[2013-14]Status: DisposedITAT Delhi18 Mar 2026AY 2013-14

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 132ASection 153DSection 28

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘F’: NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI

ACIT, New Delhi vs. Corporate International Financial Services Limited, Delhi

In the result, Cross Objection No

ITA 4806/DEL/2025[2013-14]Status: DisposedITAT Delhi18 Mar 2026AY 2013-14

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalassistant Commissioner Of Income Vs Corporate International Tax, Central Cordcle-04, Room No. Financial Services Limited 333, 3Rd Floor, Ara Centre, Sector B Pkt-1, Vasant Jhandewalan Extension , New Delhi Kunj, South Delhi, Delhi Pan: Aaack0329B Appellant Respondent C.O No. 270/Del/2025 In Ita No. 4806/Del/2025 Corporate International Financial Vs Assistant Commissioner Of Services Limited Income Tax, Central Sector B Pkt-1, Vasant Kunj, South Cordcle-04, Room No. 333, Delhi, Delhi 3Rd Floor, Ara Centre, Pan: Aaack0329B Jhandewalan Extension , New Delhi Appellant Respondent Assessee By Sh. Somil Aggarwal, Adv & Sh. Deepesh Garg, Adv Revenue By Sh. Dayainder Singh Sidhu, Cit Dr Date Of Hearing 16/03/2026 Date Of Pronouncement 18/03/2026 Order Per Yogesh Kumar, U.S. Jm: The Captioned Appeal Is Filed By The Revenue & The Cross Objection Is Filed By The Assessee Against The Order Of The Commissioner Of Income Tax Appeal, (Ld. Cit(A) For Short) Delhi-23 Dated 24/04/2025 Pertaining To Assessment Year 2013-14. 2. The Ld. Counsel For The Assessee Addressing On The Ground No. 3 Of Cross Objection, Contended That The Assessment Order Has Been Passed Based On The Invalid Approval Accorded Under Section 153D Of 2Ita No. 4806/D/2025 & C.O. No. 270/D/2025 Acit Vs. Corporate International

Section 153D

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘C’ NEW DELHI) BEFORE YOGESH KUMAR U.S., JUDICIAL MEMBER AND SHRI

Ild Millennium Pvt Ltd, Delhi vs. Civic Center, Delhi

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

ITA 4735/DEL/2025[2015-16]Status: DisposedITAT Delhi18 Mar 2026AY 2015-16

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2015-16

Section 115JSection 142(1)Section 143(2)Section 143(3)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SH. SUDHIR KUMAR, JUDICIAL MEMBER & SH. MANISH AGARWAL

Ambe Marble, New Delhi vs. ITO Ward 36(1), Delhi, New Delhi

In the result, appeal of the assessee is allowed

ITA 4722/DEL/2025[2017-18]Status: DisposedITAT Delhi18 Mar 2026AY 2017-18

Bench: Sh. Sudhir Kumar & Sh. Manish Agarwalassessment Year: 2017-18 Ambe Marble Ito Ward 36(1) Delhi New C/O B-50 Lgf South Vs Delhi Extension Part-Ii, New Delhi Pan No. Abbfa5852G (Appellant) (Respondent)

Section 115BSection 142(1)Section 143(2)Section 143(3)Section 68

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SH. SUDHIR KUMAR, JUDICIAL MEMBER & SH. MANISH AGARWAL

Deputy Commissioner of Income Tax, Central Circle-20, Delhi, Jhandewalan vs. Krska Capital Private Limited, Delhi

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

ITA 4666/DEL/2025[2016-17]Status: DisposedITAT Delhi18 Mar 2026AY 2016-17

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2016-17

Section 132(4)Section 143(3)Section 147Section 148Section 68

THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH “B”NEWDELHI BEFORE SHRI SUDHIR KUMAR, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT

Shri Parasram Commodities Pvt Ltd., Delhi vs. DCIT, Circle-23(1), Delhi

In the result the appeal of the assessee is allowed

ITA 4630/DEL/2025[2012-13]Status: DisposedITAT Delhi18 Mar 2026AY 2012-13

Bench: Shri Sudhir Kumar & Shri Manish Agarwalassessment Year: 2012-13

Section 143(3)Section 147Section 148Section 68

NFAC) arising out from the assessment order dated 31-12-2019 passed by the Assessing Officer for A.Y. 2012-13 under the section 143(3)/147 of the Income Tax Act, 1961(In short “the Act”). 1 2. The brief facts of the case are that the assessee has filed

Amazon Smart Commerce Solutions Private Limited, Delhi vs. Principal Commissioner of Income Tax, Delhi-1, Delhi

ITA 3533/DEL/2025[2021-22]Status: DisposedITAT Delhi18 Mar 2026AY 2021-22

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 143(1)Section 143(3)Section 263Section 40A(2)

Delhi-1 [“Ld. CIT(A)”, for short] dated 28.03.2025 for the Assessment Year 2021-22 and the assessment order was passed under section 143(3) r.w.s.263 of the Income-tax Act, 1961 (for short ‘the Act'). 2. Brief facts of the case are, the assessee filed its return of income ... huge advertisement expenses was allowed without verification by the learned AO. After discussing the above various issues in the assessment order completed under Section 143(3) of the Act, the learned PCIT invoked Explanation 2 to Section 263 of the Act and observed that the order was passed without making

Amrik Singh Through Legal Heir Kawalpreet Kaur, Ghaziabad vs. Income Tax Officer, Ward 1(5), Ghaziabad

In the result, the Appeal of the Assessee is partly allowed for statistical purpose

ITA 1366/DEL/2025[2014-15]Status: DisposedITAT Delhi18 Mar 2026AY 2014-15

Bench: Yogesh Kumar U.S. & Shri Manish Agarwalamrik Singh Through Legal Heir Vs Income Tax Officer, Ward Kawalpreet Kaur, 1(5), Ghaziabad, 206, Ground Floor, Niti Khand-1, Uttar Pradesh Indirapuram, Ghaziabad Pan: Achps0677E Appellant Respondent Assessee By None Revenue By Sh. Om Prakash, Sr. Dr Date Of Hearing 17/03/2026 Date Of Pronouncement 18/03/2026 Order Per Yogesh Kumar, U.S. Jm: This Appeal Is Filed By The Legal Heir Of The Assessee Challenging The Order Of The Commissioner Of Income Tax (Appeals)- Ghaziabad (‘Ld. Cit(A)’ For Short) Dated 31/08/2018 Pertaining To The Assessment Year 2014-15. 2. None Appeared For The Appellant. Considering The Issue Involved In The Present Appeal We Deem It Fit To Decide The Appeal On Hearing The Ld. Department'S Representative & Perused The Material Available On Record.

Section 143(3)

days in filing the present Appeal. 7. Brief facts of the case are that, an assessment order came to be passed under Section 143(3) of the Income Tax Act, 1961 (‘Act’ for short) on 29/12/2016 by computing the income of the Assessee

M.K. Gupta and Sons HUF, C/O Ca Sahil Gupta vs. ITO Ward 59(6), Income Tax Department

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

ITA 915/DEL/2024[2017-18]Status: DisposedITAT Delhi18 Mar 2026AY 2017-18

Bench: Shri Raj Kumar Chauhan, Hon’Ble & Smt. Renu Jauhri, Hon’Ble

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

915_DEL_2024_M.K.GUPTA AND SONS HUF IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘E’, NEW DELHI BEFORE SHRI RAJ KUMAR CHAUHAN