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“Section 142(1)”

Section References (mined)Section 142Section 142(1)15,051 judgments

The decision most relied on for Section 142(1) is Collector, Land Acquisition v. Mst. Katiji (167 ITR 471), cited in 3,926 judgments on BharatTax.

Leading authorities on Section 142(1)

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.

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. 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.

Estate of Late Tukojirao Holkar v. CWT
223 ITR 480 · 1997 · High Court
2,040
citing judgments

A court or tribunal is not bound to answer a reference or adjudicate an appeal on its merits if the party at whose instance the proceeding is made fails to appear at the hearing or take necessary steps for its proper conduct.

Sumati Dayal v. CIT
214 ITR 801 · 1995 · Supreme Court
1,967
citing judgments

The Revenue is entitled to look behind the apparent form of a transaction to discover its true nature, applying the test of human probabilities and surrounding circumstances. If transactions defy logic or are unnatural, they can be treated as bogus, even if supported by some documentation, especially in cases of cash credits or unexplained investments.

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

CIT v. B.N. Bhattacharya & Another
118 ITR 461 · 1997 · Supreme Court
1,656
citing judgments

Appealing a tax assessment requires more than just filing the appeal; it involves actively pursuing it. The assessee must effectively engage with the appellate process.

CIT v. Durga Prasad More
82 ITR 540 · 1971 · Supreme Court
1,579
citing judgments

Tax authorities must judge evidence using the test of human probabilities and consider the apparent as real until there are reasons to believe it is not. They can rely on circumstantial evidence and the preponderance of probabilities to determine the genuineness of transactions.

Judgments citing Section 142(1)

Rama Rani, Chandigarh vs. DCIT, Circle 1(1), Chandigarh

The appeal stand allowed in terms of our above order

ITA 933/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh04 Jul 2025AY 2015-16

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No. 933/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2015-16 Ms. Rama Rani Dcit बनाम/ Vs. H. No 1058, Popular Enclave Circle 1(1), Sector 48-B, Chandigarh Chandigarh. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aerpr-2072-Q (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Ravinder Krishan (Advocate)– Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Rajat Kumar Kureel (Cit) – Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 30-06-2025 घोषणाकीतारीख /Date Of Pronouncement : 04-07-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. By Way Of This Appeal, The Assessee Assails Invocation Of Revisionary Jurisdiction U/S 263 By Ld. Pr. Commissioner Of Income Tax, Chandigarh-1 (Pr.Cit) For Assessment Year (Ay) 2015-16 Vide Impugned Order Dated 14-03-2024 Proposing Revision Of Assessment As Framed By Ld. Ao U/S.147 Of The Act On 29-03-2022. The Registry Has Noted Delay Of 98 Days In The Appeal, The Condonation Of Which Has Been Sought By Ld. Ar On The Strength Of Condonation Petition Which Is Accompanied By An Affidavit Of The Assessee. It Has Been Stated That The Assessee Was Not In India When

For Appellant: Sh. Ravinder Krishan (Advocate)– Ld. ARFor Respondent: Sh. Rajat Kumar Kureel (CIT) – Ld. DR
Section 142(1)Section 143(3)Section 147Section 263Section 54F

1 IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, CHANDIGARH HYBRID HEARING BEFORE HON’BLE SHRI LALIET KUMAR, JM AND

Ttec India Customer Solutions Pvt. Ltd., Ahmedabad vs. The Pr.CIT-3, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 1026/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad04 Jul 2025AY 2020-21

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokarasstt.Year : 2020-21 Ttec India Customer Solutions Pr.Commissioner Of Private Limited, Ttec Ahmedabad Vs. Income Tax-3 Opp: L.J.College Vejalpur Off: Sg Road, Makarba Ahmedabad. Fatewadi Bo, Fatewadi Ahmedabad. Pan : Aaccm 1005A (Applicant) (Responent) : Shri Vishal Kabra, Ar Assessee By : Shri Rignesh Das, Cit-Dr Revenue By सुनवाई क" तारीख/Date Of Hearing : 03/07/2025 घोषणा क" तारीख /Date Of Pronouncement: 04/07/2025 आदेश आदेश/O R D E R आदेश आदेश

For Appellant: Shri Rignesh Das, CIT-DR
Section 142(1)Section 143(2)Section 143(3)Section 263Section 37(1)Section 80G

selected for complete scrutiny under CASS, and statutory notices under section 143(2) were issued on 29.06.2021, followed by multiple notices under section 142(1) dated 08.11.2021, 21.02.2022, and 20.07.2022. The assessee furnished its responses electronically through the ITBA portal, submitting detailed workings, explanations, and documentary evidence as called ... completed, pursuant to a detailed scrutiny proceeding initiated through notices issued under section 143(2) and several notices under section 142(1). In response to these notices, the assessee had duly furnished the financial statements including segmental P&L for the Philippines branch, tax return filed in the Philippines, reconciliation