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)

Sterlite Interlinks Limited, Gurugram vs. Deputy Commissioner of Income Tax, Circle-22(2), New Delhi

In the result, impugned order is set aside and appeal of the assessee is allowed for statistical purpose

ITA 6838/DEL/2025[2021-22]Status: DisposedITAT Delhi16 Dec 2025AY 2021-22

Bench: Shri Vikas Awasthyआअसं.6838/धिल्ली/2025 (नि.व. 2021-22) Sterlite Interlinks Ltd., Rmz Infinity, 5Th Floor, Plot No. 15, Udyog Vihar, Phase Iv, Gurugram, Haryana 122015 ...... अपीलार्थी/Appellant Pan: Aazcs-6213-R बिाम Vs. Deputy Commissioner Of Income Tax, Circle22(2), ..... प्रनिवादी/Respondent Cr Building, Ip Estate, New Delhi 110002 अपीलार्थी द्वारा/Appellant By : S/Shri Rohit Jain, Deepesh Jain & Shaurya Jain, Advocates प्रधििािीद्वारा/Respondent By : Shri Manoj Kumar, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 16/12/2025 घोषणा की निथर्थ/ Date Of Pronouncement : 16/12/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘The Cit(A)’] Dated 25.08.2025, For The Assessment Year 2021-22. 2. Shri Rohit Jain, Appearing On Behalf Of The Assessee Submits That The Assessee Had Filed Return Of Income For Ay 2021-22 Declaring Total Income Of Rs.49,74,190/- . The Assessee In Its Return Of Income Had Claimed Refund Of Rs.3,01,52,020/-. The Return Of Assessee Was Processed U/S. 143(1) Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’) & Intimation Dated 29.12.2022 Was Communicated To The Assessee Raising A Demand Of Rs.7,52,58,450/-. The Assessee

For Appellant: S/Shri Rohit Jain, Deepesh Jain &For Respondent: Shri Manoj Kumar, Sr. DR
Section 143(1)Section 154

Shree Bhogawati Sahakari Sakhar Karkhana Ltd, Kolhapur vs. ACIT, Circle-1, Kolhapur

In the result, the appeal of the assessee in ITA

ITA 2198/PUN/2024[2014-15]Status: DisposedITAT Pune15 Dec 2025AY 2014-15

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2194 To 2198/Pun/2024 िनधा"रण वष" / Assessment Years : 2010-11 To 2014-15 Shree Bhogawati Sahakari Vs. Acit, Circle-1, Sakhar Karkhana Ltd., Kolhapur. Shahunagar Parite, Sugar Factory, Shahunagar Parite, Tal- Karveer, Kolhapur- 416211. Pan : Aaaas3731R Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amit Bobde Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2010-11 To 2014-15 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2194/Pun/2024 For A.Y. 2010-11 For Adjudication As The Lead Case.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde
Section 143(1)Section 143(3)Section 250Section 36Section 36(1)

Shree Bhogawati Sahakari Sakhar Karkhana Ltd, Kolhapur vs. ACIT, Circle-1, Kolhapur

In the result, the appeal of the assessee in ITA

ITA 2197/PUN/2024[2013-14]Status: DisposedITAT Pune15 Dec 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2194 To 2198/Pun/2024 िनधा"रण वष" / Assessment Years : 2010-11 To 2014-15 Shree Bhogawati Sahakari Vs. Acit, Circle-1, Sakhar Karkhana Ltd., Kolhapur. Shahunagar Parite, Sugar Factory, Shahunagar Parite, Tal- Karveer, Kolhapur- 416211. Pan : Aaaas3731R Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amit Bobde Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2010-11 To 2014-15 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2194/Pun/2024 For A.Y. 2010-11 For Adjudication As The Lead Case.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde
Section 143(1)Section 143(3)Section 250Section 36Section 36(1)

Shree Bhogawati Sahakari Sakhar Karkhana Ltd, Kolhapur vs. ACIT, Circle-1, Kolhapur

In the result, the appeal of the assessee in ITA

ITA 2196/PUN/2024[2012-13]Status: DisposedITAT Pune15 Dec 2025AY 2012-13

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2194 To 2198/Pun/2024 िनधा"रण वष" / Assessment Years : 2010-11 To 2014-15 Shree Bhogawati Sahakari Vs. Acit, Circle-1, Sakhar Karkhana Ltd., Kolhapur. Shahunagar Parite, Sugar Factory, Shahunagar Parite, Tal- Karveer, Kolhapur- 416211. Pan : Aaaas3731R Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amit Bobde Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2010-11 To 2014-15 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2194/Pun/2024 For A.Y. 2010-11 For Adjudication As The Lead Case.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde
Section 143(1)Section 143(3)Section 250Section 36Section 36(1)

Shree Bhogawati Sahakari Sakhar Karkhana Ltd, Kolhapur vs. ACIT, Circle-1, Kolhapur

In the result, the appeal of the assessee in ITA

ITA 2195/PUN/2024[2011-12]Status: DisposedITAT Pune15 Dec 2025AY 2011-12

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2194 To 2198/Pun/2024 िनधा"रण वष" / Assessment Years : 2010-11 To 2014-15 Shree Bhogawati Sahakari Vs. Acit, Circle-1, Sakhar Karkhana Ltd., Kolhapur. Shahunagar Parite, Sugar Factory, Shahunagar Parite, Tal- Karveer, Kolhapur- 416211. Pan : Aaaas3731R Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amit Bobde Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2010-11 To 2014-15 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2194/Pun/2024 For A.Y. 2010-11 For Adjudication As The Lead Case.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde
Section 143(1)Section 143(3)Section 250Section 36Section 36(1)

Shree Bhogawati Sahakari Sakhar Karkhana Ltd, Kolhapur vs. ACIT, Circle-1, Kolhapur

In the result, the appeal of the assessee in ITA

ITA 2194/PUN/2024[2010-11]Status: DisposedITAT Pune15 Dec 2025AY 2010-11

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2194 To 2198/Pun/2024 िनधा"रण वष" / Assessment Years : 2010-11 To 2014-15 Shree Bhogawati Sahakari Vs. Acit, Circle-1, Sakhar Karkhana Ltd., Kolhapur. Shahunagar Parite, Sugar Factory, Shahunagar Parite, Tal- Karveer, Kolhapur- 416211. Pan : Aaaas3731R Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amit Bobde Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2010-11 To 2014-15 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2194/Pun/2024 For A.Y. 2010-11 For Adjudication As The Lead Case.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde
Section 143(1)Section 143(3)Section 250Section 36Section 36(1)