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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)

Satara Zilla Dak Karmachari Sahakari Pathsanstha, Near Suruchi Banglow, Shukrawar Peth, Satara vs. Assessing Officer Ward 2, Aaykar Bhawan, Manjunath Manor, Pawai Naka, Satara

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

ITA 2829/PUN/2025[2018-19]Status: DisposedITAT Pune22 Jan 2026AY 2018-19

Bench: Shri Manish Boradआयकर अपील सं. / Ita No.2829/Pun/2025 िनधा"रण वष" / Assessment Year : 2018-19 Satara Zilla Dak Karmachari Vs. Ito, National E- Sahakari Pathsanstha, Assessment Centre, 117/B, Near Suruchi Delhi. Banglow, Shukrawar Peth, Satara- 415002. Pan : Aapas2980K Appellant Respondent Assessee By : Shri Rajkumar Doshi Revenue By : Shri Shashank Ojha (Virtual) Date Of Hearing 13.01.2026 : Date Of Pronouncement : 22.01.2026 आदेश / Order Per Manish Borad, Am: This Appeal Filed At The Instance Of Assessee Is Directed Against The Order Of Ld. Cit(A)/Nfac Dated 24.09.2025 Which Is Arising Out Of The Assessment Order U/S 144 R.W.S. 143(3A) & 143(3B) Of The Act For Assessment Year 2018-19 Framed On 12.04.2021 By The Ito, National E-Assessment Centre, Delhi. 2. The Effective Grounds Of Appeal Raised By The Assessee Is Against The Disallowance Of Deduction Of Rs.43,54,979/- Claimed U/S 80P Of The Act. In The Grounds Of Appeal, The Assessee Also Stated That In Its Own Case For A.Y. 2020-21, Ld. Cit(A) Has Allowed The Deduction U/S 80P Of The Act. Further, The Request Has Been Made

For Appellant: Shri Rajkumar DoshiFor Respondent: Shri Shashank Ojha (Virtual)
Section 143(2)Section 144Section 80PSection 80P(2)(a)

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “SMC”, PUNE BEFORE SHRI MANISH BORAD, ACCOUNTANT MEMBER आयकर अपील सं. / ITA

Vishal Ramesh Fegade, Aurangabad vs. Assessing Officer, Ward 1(5), Aurangabad

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

ITA 2503/PUN/2025[2020-21]Status: DisposedITAT Pune22 Jan 2026AY 2020-21

Bench: Shri Manish Boradआयकर अपील सं. / Ita No.2503/Pun/2025 िनधा"रण वष" / Assessment Year : 2020-21 Vishal Ramesh Fegade, Vs. Ito, Ward- 1(5), A-B-8, Tapadia Pride, Aurangabad. Paithan Road, Aurangabad- 431001. Pan : Aanpf6699K Appellant Respondent Assessee By : Shri Anup Shaha Revenue By : Shri Shashank Ojha (Virtual) Date Of Hearing : 14.01.2026 Date Of Pronouncement : 22.01.2026 आदेश / Order Per Manish Borad, Am: This Appeal Filed At The Instance Of Assessee Is Directed Against The Order Of Ld. Cit(A)/Nfac Dated 27.08.2025 Which Is Arising Out Of The Assessment Order U/S 147 Of The Act For Assessment Year 2020-21 Framed On 17.03.2013 By The Ito, Ward-1(5), Aurangabad. 2. The Assessee Has Raised Following Grounds Of Appeal :- “1. I, Vishal Ramesh Fegade, Am A Salaried Employee & My Primary Source Of Income Is Derived Solely From My Employment. I Would Like To Explicitly State That I Have Not Made Any Cash Payments In Relation To The Purchase Of The Property In Question. All Payments Made Towards The Acquisition Of The Property Have Been Conducted Through Formal Banking Channels, Ensuring Full Transparency & Compliance With Legal Requirements. The Details Of These Payments Are Clearly Outlined In The Purchase Deed.

For Appellant: Shri Anup ShahaFor Respondent: Shri Shashank Ojha (Virtual)
Section 132Section 143(2)Section 147Section 148Section 151ASection 69

IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “SMC”, PUNE BEFORE SHRI MANISH BORAD, ACCOUNTANT MEMBER आयकर अपील सं. / ITA

Gunasekaran Mannar, Villupuram vs. Asst. Commissioner of Income Tax, Chennai

In the result, all the appeals filed by the assessee are allowed

ITA 1864/CHNY/2025[2018-19]Status: DisposedITAT Chennai22 Jan 2026AY 2018-19

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri Shiva Srinivas, CIT
Section 115BSection 132Section 139(1)Section 147Section 148

offering additional income in the form of G.P on supressed sales. Notices under Sections 143(2) and 142(1) were issued electronically on various dates and the assessee furnished details and submissions in response on 13.12.2023, 02.02.2024, and 16.02.2024. The AO also held that the income disclosed in the return

Gunasekaran Mannar, Villupuram vs. Asst. Commissioner of Income Tax, Chennai

In the result, all the appeals filed by the assessee are allowed

ITA 1858/CHNY/2025[2022-23]Status: DisposedITAT Chennai22 Jan 2026AY 2022-23

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri Shiva Srinivas, CIT
Section 115BSection 132Section 139(1)Section 147Section 148

offering additional income in the form of G.P on supressed sales. Notices under Sections 143(2) and 142(1) were issued electronically on various dates and the assessee furnished details and submissions in response on 13.12.2023, 02.02.2024, and 16.02.2024. The AO also held that the income disclosed in the return

Gunasekaran Mannar, Villupuram vs. Asst. Commissioner of Income Tax, Chennai

In the result, all the appeals filed by the assessee are allowed

ITA 1856/CHNY/2025[2020-21]Status: DisposedITAT Chennai22 Jan 2026AY 2020-21

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri Shiva Srinivas, CIT
Section 115BSection 132Section 139(1)Section 147Section 148

offering additional income in the form of G.P on supressed sales. Notices under Sections 143(2) and 142(1) were issued electronically on various dates and the assessee furnished details and submissions in response on 13.12.2023, 02.02.2024, and 16.02.2024. The AO also held that the income disclosed in the return

Gunasekaran Mannar, Villupuram vs. Asst. Commissioner of Income Tax, Chennai

In the result, all the appeals filed by the assessee are allowed

ITA 1855/CHNY/2025[2019-20]Status: DisposedITAT Chennai22 Jan 2026AY 2019-20

Bench: Shri S.S. Viswanethra Ravi & Shri S.R. Raghunathaआयकर अपील सं./I.T.A. Nos.1863, 1864, 1855, 1856, 1857 & 1858/Chny/2025 िनधा"रण वष"/Assessment Years: 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23 Gunasekaran Mannar, Vs. The Assistant Commissioner Of No. 91, Kamaraj Street, Income Tax, Villupuram 605 602, Villupuram. Central Circle 1(1), Chennai. [Pan:Aacpg0230G] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri Shiva Srinivas, Cit सुनवाई की तारीख/ Date Of Hearing : 29.10.2025 घोषणा की तारीख /Date Of Pronouncement : 22.01.2026 आदेश /O R D E R Per Bench: These Six Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 24.04.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals) - 18, Chennai For The Assessment Years 2017-18, 2018-19, 2019-20, 2020-21, 2021-22 & 2022-23. 2. Since, The Issues Raised In These Appeals Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To 2

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri Shiva Srinivas, CIT
Section 115BSection 132Section 139(1)Section 147Section 148

offering additional income in the form of G.P on supressed sales. Notices under Sections 143(2) and 142(1) were issued electronically on various dates and the assessee furnished details and submissions in response on 13.12.2023, 02.02.2024, and 16.02.2024. The AO also held that the income disclosed in the return