Section 143(1) of the Income Tax Act

Income-tax Act, 2025: s.270

Section 143(1) falls under section 143 of the Income-tax Act, 1961, which corresponds to section 270 (Assessment) of the Income-tax Act, 2025.

Read section 270 of the 2025 Act

Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.

The decision most relied on for Section 143(1) is Collector, Land Acquisition v. Mst. Katiji (167 ITR 471), cited in 3,926 of the 12,311 judgments on BharatTax that turn on this section.

Leading authorities on Section 143(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.

Goetze (India) Ltd. v. CIT
284 ITR 323 · 2006 · Supreme Court
1,842
citing judgments

An assessee cannot raise a new claim or a claim not made in the original or revised return of income for the first time directly before the Assessing Officer during assessment proceedings.

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).

CIT v. Vatika Township Pvt. Ltd.
367 ITR 466 · 2014 · Supreme Court
1,558
citing judgments

Taxing statutes are presumed to operate prospectively unless a clear contrary intention for retrospective application is evident. The law applicable for determining tax liability is that which stands on the first day of the assessment year, following the principle that law looks forward, not backward (lex prospicit non respicit).

Checkmate Services Pvt. Ltd. v. CIT
143 Taxmann.com 178 · 2022 · Supreme Court
1,392
citing judgments

Employee contributions to provident fund and ESI deposited by an employer beyond the due dates prescribed under the respective special Acts are not allowable as a deduction under section 36(1)(va) of the Income-tax Act, 1961. Such disallowance can be made during processing under section 143(1).

CIT v. Alom Extrusions Ltd.
319 ITR 306 · 2009 · Supreme Court
1,344
citing judgments

A proviso inserted into a section to remedy unintended consequences, make the section workable, or supply an obvious omission must be read retrospectively in operation to give effect to the section as a whole.

ACIT v. Rajesh Jhaveri Stock Brokers Pvt. Ltd.
291 ITR 500 · 2007 · Supreme Court
1,030
citing judgments

For initiating reassessment proceedings under Section 147, the Assessing Officer needs only prima facie material providing a reason to believe that income has escaped assessment. Conclusive proof or the sufficiency/correctness of the material is not required at the stage of issuing the notice under Section 148.

CIT v. Sun Engineering Works (P) Ltd.
198 ITR 297 · 1992 · Supreme Court
814
citing judgments

A court's pronouncement derives its scope and color from the specific questions involved in the case, thus, due regard must always be given to the questions framed before the court when interpreting its judgment.

Pr. Commissioner of Income Tax and Anr. v. Totagars Cooperative Sale Society
392 ITR 74 · 2017 · High Court
762
citing judgments

Interest income earned by a cooperative society from its investments or surplus deposits with a cooperative bank is eligible for deduction under Section 80P(2)(d) of the Income-tax Act, 1961.

279 ITR 331/149 Taxman 15 (Guj.); 5. CIT v. Sabari Enterprises
298 ITR 141 · 2008 · High Court
706
citing judgments

Employee contributions to provident fund or ESI, even if deposited after the due date specified in the respective welfare statutes, are allowable as a deduction under Section 36(1)(va) if paid before the due date for filing the income-tax return. This judgment aligns the treatment of employee contributions with employer contributions under Section 43B.

Judgments on Section 143(1)

Punch Ratna Fasteners Private Limited, Delhi vs. ACIT, Circle 19(1), Delhi

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

ITA 4066/DEL/2025[2018-19]Status: DisposedITAT Delhi24 Dec 2025AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2018-19] Punch Ratna Fasters Vs Acit Pvt.Ltd., 4/8 Third Floor, Circle-19(1) East Punjabi Bagh, Delhi Delhi-110026. Pan-Aaacp1316M Appellant Respondent Appellant By Shri Naveen Gupta, Adv. & Shri Nakul Gupta, Adv. Respondent By Shri Manish Gupta, Sr. Dr Date Of Hearing 24.12.2025 Date Of Pronouncement 24.12.2025 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By Assessee Against The Order Dated 16.05.2025 By Ld. Commissioner Of Income Tax (A), Meerut [“Ld.Cit(A)”] In Appeal No. 288/2013-14 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising Out Of The Assessment Order Dated 17.02.2021 Passed U/S 143(3) R.W.S. 143(3A) & 143(3B) Of The Act Pertaining To Assessment Year 2018-19. 2. Brief Facts Of The Case Are That The Assessee Company Is Engaged In The Business Of Manufacturing Of Cold & Hot Forged Automotive Components & Fasteners & Had Filed Its Return Of Income On 28.10.2018, Declaring Total Income Of Inr 28,88,88,610/-. Subsequently, The Said Return Of Income Was Selected For Complete Scrutiny Under Cass For The Issues Namely, (I) Expenditure Of Personal Nature & (Ii) Foreign Financial Interest. Subsequently, Notice U/S 143(2) Of The Act Was Served Upon The Assessee On 22.09.2019. Thereafter, Notices U/S 142(1) Of The Income-Tax Act 1961 Were Issued, In Response To Which, The Assessee Submitted Copies Of Relevant Documents & Explanations Online Through E- Filing Portal. After Considering The Submissions Made By The Assessee & All Relevant Materials Available On Record, Income Of The Assessee Was Assessed At Inr 29,16,01,890/- Vide Assessment Order Dated 17.02.2021 Passed U/S 143(3) Of The Act.

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250Section 37

Jalpa Uttapal Patel, Ahmedabad vs. The Pr.CIT, Ahmedabad-1, Ahmedabad

In the result, the appeal of the assessee is allowed

ITA 720/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad23 Dec 2025AY 2018-19

Bench: Shri Sanjay Garg & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No.720/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 Jalpa Uttapal Patel The Pr.Cit बनाम/ N Y Steel Corporation Ahmedabad-1 V/S. 6 Puja Apartment Ahmedabad – 380 015 Vrundavan Colony Opp. Sardar Patel Hospital Maninagar Ahmedabad – 380 008 "थायी लेखा सं./Pan: Baxpp 4020 K (अपीलाथ%/ Appellant) (&' यथ%/ Respondent) Assessee By : Shri Biren Shah, Ar Revenue By : Shri Sher Singh, Cit-Dr सुनवाई की तारीख/Date Of Hearing : 30 /09/2025 घोषणा की तारीख /Date Of Pronouncement: 23/12/2025 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Revision Order Passed By The Principal Commissioner Of Income Tax, Ahmedabad-1 (Hereinafter Referred To As “Pcit”) Dated 26/03/2025 U/S.263 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year (Ay) 2018-19. 2. The Assessee, In This Appeal, Has Contested The Very Exercise Of Revision Jurisdiction By The Ld. Pcit U/S.263 Of The Act. Jalpa Uttapal Patel Vs. Pcit Asst.Year : 2018-19 2

For Appellant: Shri Biren Shah, ARFor Respondent: Shri Sher Singh, CIT-DR
Section 143(1)Section 147Section 263Section 69C

Income Tax Officer, Ward 32(1), Kolkata vs. Satish Singh, Kolkata

In the result, appeal of the revenue is dismissed

ITA 449/KOL/2025[2018-19]Status: DisposedITAT Kolkata23 Dec 2025AY 2018-19

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyआयकर अपील सं/Ita No.449/Kol/2025 (निर्धारणवर्ा/Assessment Years :2018-2019) Ito, Ward-32(1), Kolkata Vs Satish Singh, 5B/H/6, Shibtala Lane, Kolkata-700071 Pan No. :Dswps 6446 B (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) रधजस्वकीओरसे /Revenue By : Shri Sandip Sarkar, Jcit, Sr.Dr निर्धाररतीकीओरसे /Assessee By : Shri Somnath Ghosh, Advocate सुनवाई की तारीख / Date Of Hearing : 09/12/2025 घोषणा की तारीख/Date Of Pronouncement : 23.12.2025 आदेश / O R D E R Per Rajesh Kumar, Am: This Is An Appeal Filed By The Revenue Against The Order Passed By The Ld. National Faceless Appeal Centre (Nfac), Delhi, Dated 01.01.2025For The Assessment Year2018-2019. 2. The Issue Raised In The Appeal Of Revenue Is Against The Order Of Ld. Cit(A) In Admitting The Additional Evidence Without Allowing Reasonable Opportunity To The Assessing Officer As Per Provisions Of Rule 46A Of It Rules, 1962 & Second Issue Is Against The Deletion Of Addition Of Rs.2,75,17,500/- As Made By The Ao U/S.40A(3) Of The Act In Respect Of Commission & Salary Paid By The Assessee During The Year. 3. Facts In Brief Are That The Assessee Is An Individual & Filed His Return Of Income For The A.Y. 2018-19 Declaring Total Income Of Rs. 16,36,550/-On 11/06/2019, The Return Of Income Was Processed U/S 143(1) Of The Act On 25.10.2019. Subsequently, Return Of The Assessee

For Appellant: Shri Somnath Ghosh, AdvocateFor Respondent: Shri Sandip Sarkar, JCIT, Sr.DR
Section 143(1)Section 40A(3)

Deputy Commissioner of Income Tax, Central Circle-4(3), Kolkata vs. Gaurang Alloys and Iron Limited, Kolkata

In the result, the appeal of the revenue is dismissed

ITA 1257/KOL/2025[2020-21]Status: DisposedITAT Kolkata23 Dec 2025AY 2020-21

Bench: Shri Rajesh Kumar, Accountantmember & Shri Pradip Kumar Choubey, Judicialmember Assessment Year: 2020-21 Dcit, Central Circle-4(3), Kolkata…....………..............................……….……Appellant Vs. Gaurang Alloys & Iron Ltd...………….……………………...……...…..…..Respondent 402A, Mangalam, 24/26, Hemanta Basu Sarani, Kol-1.. [Pan: Aaccg1485A] Appearances By: Dr. Anup Biswas, Cit-Dr,Appeared On Behalf Of The Appellant. Shri S. Jhajharia, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 30, 2025 Date Of Pronouncing The Order :December 23, 2025 Order Per Rajesh Kumar: This Is An Appeal Preferred By The Revenue Against The Order Of The Cit(Appeals)-27, Kolkata (Hereinafter Referred To As The “Ld. Cit(A)”] Dated 25.02.2025Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’)For The Ay 2020-21. 2. The Only Issue Raised By The Revenue In This Appeal Is Against The Order Of Ld. Cit(A) Treating The Undisclosed Cash Sales/Receipts Of Rs.7,54,07,283/- As Business Transaction & Directing The Ao To Apply G.P Rate @ 6.5% To Determine The Profit From The Undisclosed Sales/Receipts.

Section 132(1)Section 139(1)Section 143(1)Section 153ASection 250Section 68