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)

Pragya Savita, Jabalpur vs. Asst. Commissioner of Income Tax, Circle 2(1), Jabalpur, Jabalur

In the result, the appeal of the assessee is dismissed

ITA 21/JAB/2025[2021-22]Status: DisposedITAT Jabalpur22 May 2025AY 2021-22

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharya.Y. 2021-22 Pragya Savita, Vs. Asst. Commissioner Of 1197-A, Sadar, Modi Bada, Cantt, Income Tax, Circle-2(1), Jabalpur, Madhya Pradesh-482001 Jabalpur Pan:Axyps7485A (Appellant) (Respondent) Assessee By: Sh. Ashok Tiwari, Advocate Revenue By: Sh. Alok Bhura, Sr. Dr Date Of Hearing: 20.05.2025 Date Of Pronouncement: 22.05.2025 O R D E R Per Nikhil Choudhary, A.M. This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Jcit(A)-2, Vadodara Under Section 250 Of The Income Tax Act, 1961, Dated 27.10.2023, Dismissing The Appeal Of The Assessee That Was Filed Against The Order Of The Adit, Cpc, Bengaluru Under Section 143(1) Dated 17.12.2022. The Grounds Of Appeal Are As Under:- “1. That The Learned Cit (A) Nafc Was Wrong In Law For Not Allowing The Deduction For Payment Of Rs. 56,39,017/- Under Section 36(1)(Vi) On Account Of Employee Contribution Of Epf & Esic Amount. Whereas The Assessee Had Deposited The Employee Contribution Of Epf & Esic On Or Before Due Date For Furnishing Return Of Income Under Sub-Section (1) Of Section 139 Of Income Tax Act, 1961. Employer Is Entitled For Deduction. 2. That The Both Employee Contribution Epf Rs.49,38,777/- & Esic Rs.70,0240/- Total Rs. 59,39,107/-Which Has Been Deposited With A Small Delay Due To Unavoidable Circumstances & Covid-19. Whereas The Assessee Had Deposited The Employee Contribution Before Filing Of The Return.

For Appellant: Sh. Ashok Tiwari, AdvocateFor Respondent: Sh. Alok Bhura, Sr. DR
Section 139Section 143(1)Section 234ASection 234BSection 234CSection 250Section 36(1)(vi)