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)

Shri Panchtalavada Seva Sahkari Mandli Limited, Amreli vs. The ITO Ward-3(1)(4), Rajkot-Amreli., Amreli

In the result, this appeal of the assessee is dismissed as withdrawn

ITA 118/RJT/2025[2019-20]Status: DisposedITAT Rajkot23 Jul 2025AY 2019-20

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./ Ita No.118/Rjt/2025 Assessment Year: 2019-20 Shri Panchtalavada Seva Sahkari Income Tax Officer, Ward – बनाम Mandali Ltd. 3(1)(4), Rajkot-Amreli, Panchtalavada, Amreli–3650220, Ganga Bhauvan, Keriya /Vs. Gujarat Road, Amreli–365 560 "थायीलेखासं /.जीआइआरसं . / Pan/Gir No.: Aaxas 4713 J (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Ms. Devina Patel, Ld.Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाई क" तार"ख /Date Of Hearing : 23/07/2025 घोषणा क" तार"ख /Date Of Pronouncement : 23/07/2025 आदेश / O R D E R Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year 2019-20, Is Directed Against The Order Passed, Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’), By The Learned Commissioner Of Income Tax (Appeal) Addl/Jcit(A)-2, Hyderabad Dated 06.01.2025, Which In Turn Arises, Out Of An Assessment Order Passed By The Centralized Processing Centre (Cpc)/Assessing Officer, U/S 143(1) Of The Act Dated 08.02.2021. 2. At The Outset, Learned Counsel Appearing On Behalf Of The Assessee Has Stated That The Assessee Wants To Withdraw The Present Appeal Because Condonation Of Delay For Filing Income Tax Return U/S 119(2)(B) Of The Act Has Been Condoned Sh. Pssm Ltd.

For Appellant: Ms. Devina Patel, Ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 119(2)(b)Section 143(1)Section 250

Manoj Singh, Howrah vs. ITO, Ward 40(1), Kolkata

In the result, all the appeals of the assessee are partly allowed for statistical purposes

ITA 832/KOL/2025[2022-2023]Status: DisposedITAT Kolkata23 Jul 2025AY 2022-2023

Bench: Shri George Mathanआयकर अपील सं/Ita Nos.829-832/Kol/2025 (नििाारण वर्ा / Assessment Year :2019-2020 To 2022-2023) Manoj Singh, Vs Ito, Ward-40 (1), Kolkata 406/1, G. T.Road (South) Howrah, West Bengal-711103 Pan No. : Alpps 5330 M (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) : Shri Sunil Surana, Ar नििााररती की ओर से /Assessee By राजस्व की ओर से /Revenue By : Shri Shankar Naskar, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 23/07/2025 घोषणा की तारीख/Date Of Pronouncement : 23/07/2025 आदेश / O R D E R These Are The Appeals Filed By The Assessee Against The Separate Orders Of The Ld. Addl.Jcit(A)-2, Jaipur, Dated 26.03.2025 For The Assessment Year 2019-2020, 2020-2021, 2021-2022 & 2022-2023, Respectively. 2. Shri Sunil Surana, Ld.Ar Appeared On Behalf Of The Assessee & Shri Shankar Naskar, Ld. Sr.Dr Appeared On Behalf Of The Revenue. 3. During The Course Of Hearing, It Was Submitted By The Ld. Ar That The Ld. Cit(A) Has Dismissed The Appeals Of The Assessee Without Condoning The Delay. It Was The Submission That The Assessee Was Pursuing Alternative Remedy By Filing Rectification Application U/S.154 Of The Act Before The Ao & The Same Has Not Been Disposed Off By The Ld.Ao, Therefore, The Assessee Could Not File The Appeals Before The Ld. Cit(A) Within The Prescribed Time Limit. It Was The Submission That During The Pendency Of The Rectification Application The Assessee Opted To File Appeals Against The 2

For Respondent: Shri Shankar Naskar, Sr. DR
Section 143(1)Section 154

Manoj Singh, Howrah vs. ITO, Ward 40(1), Kolkata

In the result, all the appeals of the assessee are partly allowed for statistical purposes

ITA 831/KOL/2025[2021-2022]Status: DisposedITAT Kolkata23 Jul 2025AY 2021-2022

Bench: Shri George Mathanआयकर अपील सं/Ita Nos.829-832/Kol/2025 (नििाारण वर्ा / Assessment Year :2019-2020 To 2022-2023) Manoj Singh, Vs Ito, Ward-40 (1), Kolkata 406/1, G. T.Road (South) Howrah, West Bengal-711103 Pan No. : Alpps 5330 M (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) : Shri Sunil Surana, Ar नििााररती की ओर से /Assessee By राजस्व की ओर से /Revenue By : Shri Shankar Naskar, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 23/07/2025 घोषणा की तारीख/Date Of Pronouncement : 23/07/2025 आदेश / O R D E R These Are The Appeals Filed By The Assessee Against The Separate Orders Of The Ld. Addl.Jcit(A)-2, Jaipur, Dated 26.03.2025 For The Assessment Year 2019-2020, 2020-2021, 2021-2022 & 2022-2023, Respectively. 2. Shri Sunil Surana, Ld.Ar Appeared On Behalf Of The Assessee & Shri Shankar Naskar, Ld. Sr.Dr Appeared On Behalf Of The Revenue. 3. During The Course Of Hearing, It Was Submitted By The Ld. Ar That The Ld. Cit(A) Has Dismissed The Appeals Of The Assessee Without Condoning The Delay. It Was The Submission That The Assessee Was Pursuing Alternative Remedy By Filing Rectification Application U/S.154 Of The Act Before The Ao & The Same Has Not Been Disposed Off By The Ld.Ao, Therefore, The Assessee Could Not File The Appeals Before The Ld. Cit(A) Within The Prescribed Time Limit. It Was The Submission That During The Pendency Of The Rectification Application The Assessee Opted To File Appeals Against The 2

For Respondent: Shri Shankar Naskar, Sr. DR
Section 143(1)Section 154