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)

Eveline International, Ludhiana vs. Deputy Commissioner of Income Tax, Circle-4, Ludhiana

The appeal stand allowed for statistical purposes

ITA 942/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh16 May 2025AY 2021-22

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No.942/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2021-22) M/S Everline International Dcit Circle-4 G.T.Road Aaykar Bhawan बनाम/ Vs. Ludhiana-141014 Rishi Nagar Ludhiana-141001. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaafe-3412-C (अपीलाथ"/Appellant) (""थ" / Respondent) : अपीलाथ"कीओरसे/ Appellant By : Sh. Ashwani Kumar (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Vivek Vardhan (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 14-05-2025 घोषणाकीतारीख /Date Of Pronouncement : 16-05-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2021-22 Arises Out Of An Order Of Learned Addl. / Joint Commissioner Of Income Tax (Appeals), Jaipur [Cit(A)] Dated 09-07-2024 In The Matter Of An Intimation Issued By Cpc U/S 143(1) On 30-09-2022 Adding Back Profit On Foreign Exchange Rate For Rs.8.87 Lacs As Reported By Tax Auditor In The Tax Audit Report. The Ld. Cit(A) Did Not Admit The Appeal For Want Of Condonation Of Delay Of 48 Days. The Ld. Ar Stated That The Adjustment Has Happened Due To Incorrect Reporting In Tax Audit

For Appellant: Sh. Ashwani Kumar (CA) – Ld. ARFor Respondent: Sh. Vivek Vardhan (Addl. CIT) – Ld. Sr. DR
Section 143(1)Section 154

Bajajsons Ltd., Ludhiana vs. DCIT, Central Circle III, Ludhiana

In the result, the appeal stand dismissed

ITA 935/CHANDI/2024[2021-2022]Status: DisposedITAT Chandigarh16 May 2025AY 2021-2022

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No. 935/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2021-22) M/S Bajajsons Ltd. Dcit बनाम/ C-103 Phase V Focal Point Central Circle Iii Vs. Ludhiana 141010 Ludhiana-141001 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaacb-6875-H (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sarabjit Garg (Ca) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Vivek Vardhan (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 23-04-2025 घोषणाकीतारीख /Date Of Pronouncement : 16-05-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2021- 22 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-5, Ludhiana [Cit(A)] Dated 27-06-2024 In The Matter Of An Intimation Issue By Cpc U/S 143(1) Of The Act On 04-03-2021 Disallowing Late Payment Of Employees’ Contribution To Pf / Esi For Rs.5.44 Lacs In Terms Of Sec.43B R.W.S. 36(1)(Va) As Well As Sec.2(24)(X). The Ld. Cit(A) Confirmed The Same, Inter-Alia, By Relying Upon The Decision Of Hon’Ble Apex Court In The Case Of Checkmate

For Appellant: Sh. Sarabjit Garg (CA) – Ld. ARFor Respondent: Sh. Vivek Vardhan (Addl. CIT) – Ld. Sr. DR
Section 143(1)Section 14BSection 2(24)(x)Section 36(1)(iv)Section 36(1)(va)Section 43B

Satish Kumar Rana, Kangra vs. Income Tax Officer, Kangra Himachal Pradesh

In the result, the appeal stand dismissed

ITA 1190/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh16 May 2025AY 2020-21

Bench: Hon’Ble Shri Laliet Kumar, Jm & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपील सं. / Ita No. 1190/Chandi/2024 (िनधा"रणवष" / Assessment Year: 2020-21) Shri Satish Kumar Rana Ito-Ward 42(3)(3) बनाम/ H.No. 90, Dhaniara, Duhak Mumbai Vs. Thural, Kangra, Hp – 176075 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaupr-3944-G (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Written Submissions ""थ"कीओरसे/Respondent By : Dr. Ranjit Kaur (Addl. Cit) – Ld. Sr. Dr सुनवाईकीतारीख/Date Of Hearing : 15-05-2025 घोषणाकीतारीख /Date Of Pronouncement : 16-05-2025 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2020-21 Arises Out Of An Order Of Learned Addl. / Joint Commissioner Of Income Tax (Appeals), Hyderabad [Cit(A)] Dated 18-12-2023 In The Matter Of An Intimation Issued By Cpc U/S 143(1) Of The Act On 16-12-2019. At The Time Of Hearing, None Appeared For Assessee. However, The Written Submissions As Filed By The Assessee Were Duly Considered. The Ld. Sr. Dr Stated That The Issue Stood Squarely Covered Against The Assessee By The Decision Of Hon’Ble Apex Court. The Registry Has Noted Delay Of 281 Days In The Appeal Which Stand Condoned.

For Appellant: Written SubmissionsFor Respondent: Dr. Ranjit Kaur (Addl. CIT) – Ld. Sr. DR
Section 143(1)Section 2(24)(x)Section 36(1)(iv)Section 36(1)(va)Section 43B