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“Section 143(2)”

Section References (mined)Section 143Section 143(2)17,209 judgments

The decision most relied on for Section 143(2) is National Thermal Power Co. Ltd. v. CIT (229 ITR 383), cited in 5,834 judgments on BharatTax.

Leading authorities on Section 143(2)

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.

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. 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.

CIT v. Reliance Utilities & Power Ltd.
313 ITR 340 · 2009 · High Court
2,118
citing judgments

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such 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. AIMIL Ltd.
321 ITR 508 · 2010 · High Court
1,629
citing judgments

Employee contributions to PF and ESIC, deposited beyond the due date under the respective Acts but within the due date for filing the income tax return under Section 139(1), are allowable deductions under Section 36(1)(va). Such disallowance cannot be made during processing under Section 143(1).

Judgments citing Section 143(2)

DCIT, Circle-7(1), Delhi vs. Dlf Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 714/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Oct 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

ITA No.713/Del/2024 & Others THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER

DCIT, Circle-7(1), Delhi vs. Dlf Limited, Delhi

In the result, appeal of the Revenue is dismissed

ITA 713/DEL/2024[2019-20]Status: DisposedITAT Delhi30 Oct 2025AY 2019-20

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

ITA No.713/Del/2024 & Others THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER

Dlf Limited, Delhi vs. National Faceless Assessment Centre, Delhi

In the result, appeal of the Revenue is dismissed

ITA 677/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Oct 2025AY 2021-22

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

ITA No.713/Del/2024 & Others THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER

Dlf Limited, Delhi vs. National Faceless Assessment Centre, Delhi

In the result, appeal of the Revenue is dismissed

ITA 676/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Oct 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 142(1)Section 143(2)Section 143(3)Section 14A

ITA No.713/Del/2024 & Others THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘B’, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER

Lsl Tools (P) Ltd., Gurgaon vs. ACIT, CC-1, Faridabad

In the result, both the appeals are allowed

ITA 5644/DEL/2024[2021-22]Status: DisposedITAT Delhi30 Oct 2025AY 2021-22

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha S. Gupt, CIT DR
Section 127Section 132Section 143(2)Section 143(3)Section 145(3)Section 153DSection 234CSection 40A(2)(b)

Undisputedly, during the period of search. no incriminating material appears to have been found. However, the Revenue proceeded to issue notice under Section 143(2) of the Act on the pretext of the statements or the Directors of the respondent-assessee companies recorded under Section ... Undisputedly, during the period of search, no incriminating material appears to have been found. However, the Revenue proceeded to issue notice under Section 143(2) of the Act on the pretext of the statements of the Directors of the respondent-assessee companies recorded under Section

Lsl Tools (P) Ltd, Gurugram vs. ACIT, Central Circle-1, Faridabad

In the result, both the appeals are allowed

ITA 5643/DEL/2024[2020-21]Status: DisposedITAT Delhi30 Oct 2025AY 2020-21

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha S. Gupt, CIT DR
Section 127Section 132Section 143(2)Section 143(3)Section 145(3)Section 153DSection 234CSection 40A(2)(b)

Undisputedly, during the period of search. no incriminating material appears to have been found. However, the Revenue proceeded to issue notice under Section 143(2) of the Act on the pretext of the statements or the Directors of the respondent-assessee companies recorded under Section ... Undisputedly, during the period of search, no incriminating material appears to have been found. However, the Revenue proceeded to issue notice under Section 143(2) of the Act on the pretext of the statements of the Directors of the respondent-assessee companies recorded under Section

Deputy Commissioner of Income Tax, Delhi vs. La Solitaire Jewels Private Limited, Delhi

The Appeal of the Revenue is dismissed

ITA 181/DEL/2024[2017-18]Status: DisposedITAT Delhi30 Oct 2025AY 2017-18

Bench: Shri Yogesh Kumar U.S. & Shri Avdhesh Kumar Mishradeputy Commissioner Of Vs La Solitaire Jewels Income Tax, Private Limited Room No. 316A, C. R. 2706, Bank Street Road, Building, I. P. Estate, Karol Bagh, New Delhi- New Delhi 110005 Delhi Pan: Aaacl9483H Appellant Respondent Assessee By Sh. Mayankpatwari, Adv & Sh. Akashojha, Adv Revenue By Sh. Gouranga Chandra, Sr. Dr Date Of Hearing 27/08/2025 Date Of Pronouncement 30/10/2025

Section 143(2)Section 143(3)Section 145Section 145(3)Section 68

1 DCIT Vs. La solitaire Jewels Pvt. Ltd. IN THE INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘E’ NEW DELHI

Rajendra Kumar Sahi, Ranchi vs. CIT (Appeal), Delhi

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

ITA 148/RAN/2025[2022-23]Status: DisposedITAT Ranchi29 Oct 2025AY 2022-23

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.148/Ran/2025 Assessment Year: 2022-23 Rajendra Kumar Sahi………….……………............................……….……Appellant Hulhundu, Hatia, Ranchi, Jharkhand – 834003. [Pan: Agkps0098L] Vs. Cit(Appeal), Jharkhand….....…..….…..….........……........……...…..…..Respondent Appearances By: None Appeared On Behalf Of The Appellant. Shri Khubchand T. Pandya, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 29, 2025 Order Per Sonjoy Sarma: This Appeal By The Assessee Is Directed Against The Order Of The Nfac, Delhi [“Cit(A)”] Dated 07.08.2024 Under Section 250 Of The Income-Tax Act, 1961 (The “Act”) For The Assessment Year 2022–23. 2. Brief Facts Of The Case Are That The Assessee Filed The Return Of Income For The Assessment Year 2022–23 Declaring A Total Income Of ₹4,96,520. The Case Was Selected For Scrutiny As The Assessee Had Disclosed Comparatively Low Income Against Receipts On Which Tcs Had Been Deducted. The Assessing Officer (Ao) Noted A Possibility That The Assessee Had Shown Low Income In Order To Reduce Taxable Profits. It Was Also Observed That The Assessee Had Claimed Significantly Higher Tds In The Revised Itr. Therefore, The Ao Intended To Verify The Genuineness Of The Additional Tds Claim & Whether The Corresponding Receipts Had Been Offered To Tax. Accordingly, Notices Under Sections 143(2) & 142(1) Of The Income-Tax Act Were Issued To The Assessee. However, The Assessee Did Not Comply With The Notices. Consequently, The Ao

Section 250

intended to verify the genuineness of the additional TDS claim and whether the corresponding receipts had been offered to tax. Accordingly, notices under sections 143(2) and 142(1) of the Income-tax Act were issued to the assessee. However, the assessee did not comply with the notices. Consequently

Naranji Rajaram Dave, Porbandar vs. Income-Tax Officer, Ward-2(3), Porbandar, Gujarat

In the result, the appeal of the assessee is allowed

ITA 822/RJT/2024[2017-18]Status: DisposedITAT Rajkot29 Oct 2025AY 2017-18

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकरअपीलसं./Ita No. 822/Rjt/2024 ("नधा"रणवष"/Assessment Year: (2017-18) Naranji Rajaram Dave, Income Tax Officer, Wd -2(3), Vs. Porbandar-360575 17, 17 Naranji Rajaram Dave, Suttar Vada, Porbandar, Suttar Vada, Porbandar-360575 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Acjpd8823B (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri Sagar Shah, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 133(6)Section 139Section 143(2)Section 143(3)Section 250Section 60

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

Bader Sultan Kakad, Palakkad vs. ITO, Ward-1, Palakkad

In the result, the appeal of the assessee bearing ITA No

ITA 591/COCH/2025[2016-17]Status: DisposedITAT Cochin29 Oct 2025AY 2016-17

Bench: Shri Inturi Rama Rao, Am & Shri Anikesh Banerjee, Jm Assessment Year: 2016-17 Bader Sultana Kakad .......... Appellant 11/460 Metro Bazar, Market Road Palakkad 678014 [Pan: Agtpb9696A] Vs. The Income Tax Officer, Ward -1, Palakkad ......... Respondent Assesseeby: Shri Sivadas Chettor, Ca Revenue By: Smt. Leena Lal, Sr. D.R. Date Of Hearing: 27.10.2025 Date Of Pronouncement: 29.10.2025

For Appellant: Shri Sivadas Chettor, CAFor Respondent: Smt. Leena Lal, Sr. D.R
Section 143(2)Section 148Section 148ASection 250Section 271Section 271(1)(b)

notice under 4 Bader Sultana Kakad section 148 of the Act, she could not comply with the subsequent notices issued under sections 143(2) and 142(1) due to medical reasons and limited technical knowledge.It is noted that the assessee made do compliance on 04.05.2024 during the penalty proceedings

Janta Land Promoters Pvt Ltd, Mohali vs. The Prinicipal Commissioner of Income Tax, Chandigarh-1, Chandigarh

In the result, appeal of the Assessee is allowed

ITA 618/CHANDI/2025[2020-2021]Status: DisposedITAT Chandigarh29 Oct 2025AY 2020-2021
For Appellant: Shri Pankaj Bhalla, C.AFor Respondent: Shri Manav Bansal, CIT, DR
Section 143(3)Section 194Section 263Section 68

speaks for itself that within the parameter of Section 143(3) he has passed the assessment order dt. 12/06/2020 as requisite notice under section 143(2) of the Act dt. 22/09/2019 was issued to the assessee firm and that the same was served upon the assessee in time. c) Delhi

Vidya Vikas Pratishtan, Solapur vs. DCIT, Exemption Circle, Pune

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

ITA 902/PUN/2025[2022-23]Status: DisposedITAT Pune29 Oct 2025AY 2022-23

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.902/Pun/2025 िनधा"रण वष" / Assessment Year : 2022-23 Vidya Vikas Pratishtan, Vs. Assessment Unit, 72/2B, Pratap Nagar, Income Tax Department. Soregaon, Solapur- 413004. Pan : Aaatv8537F Appellant Respondent Assessee By : Shri Piyush Bafna Revenue By : Shri Amit Bobde Date Of Hearing : 18.08.2025 Date Of Pronouncement : 29.10.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.12.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2022-23. 2. There Is Delay In Filing Of The Present Appeal. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Applicant Was Prevented By Sufficient Cause For Not Filing The Appeal Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeal.

For Appellant: Shri Piyush BafnaFor Respondent: Shri Amit Bobde
Section 143(1)(a)Section 143(2)Section 143(3)Section 250Section 250(6)Section 69A

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “B”, PUNE BEFORE SHRI MANISH BORAD, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE

Shobharam Tulshiram Prajapat, Jalgaon vs. ITO, Ward 1(3), Jalgaon

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

ITA 2128/PUN/2025[2015-16]Status: DisposedITAT Pune29 Oct 2025AY 2015-16

Bench: Dr.Manish Borad

For Appellant: Shri Vinay KawdiaFor Respondent: Shri Ajitesh Meena
Section 143(2)Section 144Section 147Section 148Section 153CSection 69A

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “SMC”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER आयकर अपील सं. / ITA No.2128/PUN/2025

Tangmarg Investment and Trading Pvt.Ltd, Pune vs. ACIT, Circle-7, Pune

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

ITA 1878/PUN/2025[2017-18]Status: DisposedITAT Pune29 Oct 2025AY 2017-18

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.1878/Pun/2025 Assessment Year : 2017-18

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Bharat Andhale
Section 143(2)Section 144Section 249(2)

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCHES “B”, PUNE BEFORE DR.MANISH BORAD, ACCOUNTANT MEMBER AND SHRI VINAY BHAMORE, JUDICIAL

Satish Vishnu Thombare, Income Tax Officer, Ward-1, Ahmednagar vs. Varsha Prafulla Zende, Ahmednagar

In the result, the appeal of the Revenue is dismissed

ITA 1656/PUN/2024[2010-11]Status: DisposedITAT Pune29 Oct 2025AY 2010-11

Bench: Shri R.K. Panda & Ms. Astha Chandraआयकर अपील सं. / Ita No.1656/Pun/2024 धििाारण वर्ा / Assessment Year : 2010-11 Satish Vishnu Thombare, Varsha Prafulla Zende, Income Tax Officer, Prop Of Bleach Chem Enterprises, Ward-1, Ahmednagar Vs. Industrial Estate, Shrirampur, Maharashtra-413709 Pan : Aabpz2541C अपीलार्थी / Appellant प्रत्यर्थी / Respondent Assessee By : Miss Shivani Shah (Virtual) Department By : Shri Akhilesh Srivastva Date Of Hearing : 06-08-2025 Date Of 29-10-2025 Pronouncement : आदेश / Order

For Appellant: Miss Shivani Shah (Virtual)For Respondent: Shri Akhilesh Srivastva
Section 132(1)Section 147Section 148Section 151Section 68

case, the sanction had been granted without any application of mind. 7. On 09/10/2019, Respondent No.1 issued a notice under Section 143(2) of the Act and Section 142(1) of the Act requesting Petitioner to attend his office on 16/10/2019 at 11.00 a.m. Petitioner, vide order dated 15/10/2019, informed

Nagesh Panjala, Warangal vs. ITO., Ward-1, Warangal

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

ITA 874/HYD/2024[2017-18]Status: DisposedITAT Hyderabad29 Oct 2025AY 2017-18
Section 142(1)Section 143(2)Section 147Section 148Section 151Section 250Section 69A

आयकर अपीलीय न्यायाधिकरण में, हैदराबाद 'ए' बेंच, हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad 'A‘ Bench, Hyderabad श्री मंजूनाथ

Knr Constructions Limited, Hyderabad vs. ACIT, Central Circle-2(2), Hyderabad

In the result, appeal filed by the assessee is dismissed

ITA 500/HYD/2022[2018-19]Status: DisposedITAT Hyderabad29 Oct 2025AY 2018-19
For Appellant: Shri A.V.Raghuram, AdvocateFor Respondent: : Smt. U Mini Chandran, CIT(DR)
Section 143(2)Section 143(3)Section 144CSection 144C(13)Section 144C(5)Section 80Section 92C

declaring total income of Rs.57,99,54,680/-. The case of the assessee was selected for scrutiny, and accordingly, notice under section 143(2) of the Act was issued by the Ld. AO on 22.09.2019. During the year, the assessee had entered into specified domestic transactions with its Associated Enterprises

Grand Ark Logistics Pvt. Ltd., Chennai vs. DCIT, Corp. Circle-1(1), Chennai

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

ITA 862/CHNY/2025[2021-22]Status: DisposedITAT Chennai29 Oct 2025AY 2021-22

Bench: Ms. Padmavathy S & Shri Manu Kumar Giri

For Appellant: Shri Arjun Raj, AdvocateFor Respondent: Ms. Gouthami Manivasagam, JCIT
Section 133(6)Section 142Section 143(3)Section 191C(6)Section 194C(6)Section 40

report in Form No.3CA — 3CD 3. 30.11.2021 | Audited Financials 22 4. 02.03.2022 | Statement of Income 55 SCRUTINY ASSESSMENT PROCEEDINGS 5. 28.06.2022 | Notice under Section 143(2) of the Act 59 6. 04.08.2022 | Reply to Notice under Section 142(1) of the Act dated | 62 18.07.2022 7. 19.10.2022 | Reply to Notice

Arjun Shetty, Mangaluru vs. Income Tax Officer, Tps, Circle - 1(1), Mangaluru

In the result, appeal filed by the assessee is allowed

ITA 61/BANG/2025[2018-19]Status: DisposedITAT Bangalore29 Oct 2025AY 2018-19

Bench: Shri.Laxmi Prasad Sahu & Shri.Keshav Dubeyassessment Year : 2018-19 Arjun Shetty, Vs. Ito, 16-6-393/9 Shubha Krishna Building, Ward – Tps, Highland Falnir, Mangalore - 575002. Circle – 1(1), Pan :Ainps5294H Mangalore. Appellant Respondent Assessee By : S/Shri. Pranav G Ambekar, V. Narendra Sharma, Advocates Revenue By : Shri. Nilanjan Dey,Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 15.09.2025 Date Of Pronouncement : 29.10.2025

For Appellant: S/Shri. Pranav G Ambekar, V. Narendra Sharma, AdvocatesFor Respondent: Shri. Nilanjan Dey,JCIT(DR)(ITAT), Bangalore
Section 10Section 10(1)Section 143(2)Section 143(3)Section 250

income on 17.09.2018 admitting total income of Rs.1,00,38,530/-. The case was selected for limited scrutiny under CASS. Accordingly, notice under section 143(2) of the Act dated 23.09.2019 was Page 2 of 16 issued to the assessee to verify the agricultural income of Rs.81 ... under CASS for the reason of “Large Agricultural income”. The learned Assessing Officer (hereinafter referred to as the learned “AO”) issued notices under section 143(2) of the Act requesting the appellant to produce the documentary evidence for location of land, crops grown in respect of agricultural income. Page

Narayana Singh Chaya Kumari, Bengaluru vs. Income Tax Officer, Ward-6(2)(2), Bengaluru

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

ITA 415/BANG/2025[2017-18]Status: DisposedITAT Bangalore29 Oct 2025AY 2017-18

Bench: Shri.Laxmi Prasad Sahu & Shri.Keshav Dubeyassessment Year : 2017-18 Ms. Narayana Singh Chaya Kumari, Vs. Ito, #34, 8Th Cross, Saraswathipuram, Ward – 6(2)(2), Bangalore – 560 096. Bangalore. Pan : Ajxpk 5639 D Appellant Respondent Assessee By : Shri. Likith Patel, Advocate Revenue By : Shri. Subramanian S,Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 09.10.2025 Date Of Pronouncement : 29.10.2025

For Appellant: Shri. Likith Patel, AdvocateFor Respondent: Shri. Subramanian S,JCIT(DR)(ITAT), Bangalore
Section 143(1)Section 143(2)Section 250Section 69A

case was selected for scrutiny through CASS reason being cash deposited during demonetization period and investment in immovable property. Accordingly, notice under section 143(2) of the Act was issued to the assessee and other statutory notices were issued. Assessee furnished copy of sale deeds, copies of invoice, bank statement