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)

Arya Financial and Investment Consultancy Services Pvt Ltd, Mumbai vs. ITO, Ward 6(1)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 2597/MUM/2022[2020-21]Status: DisposedITAT Mumbai23 Dec 2022AY 2020-21

Bench: Shri Aby T. Varkey, Jm & Shri M. Balaganesh, Am आयकर अपील सं/ I.T.A. No. 2597/Mum/2022 (निर्धारण वर्ा / Assessment Year: 2020-21) Arya Financial & बिधम/ Ito, Ward-6(1)(1) Investment Consultancy M. K. Road, New Marine Vs. Services Pvt. Ltd. Lines, Mumbai-400020. 801C Wing Godrej Coliseum Off Somaiya Hospital Road, Sion East, Mumbai-400022. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaaca9622P (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) Assessee By: Shri Hitesh Trivedi Revenue By: Shri Vaibhav Jain सुनवाई की तारीख / Date Of Hearing: 14/12/2022 घोषणा की तारीख /Date Of Pronouncement: 23/12/2022 आदेश / O R D E R Per Aby T. Varkey, Jm: This Is An Appeal Preferred By The Assessee An Individual Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)/Nfac. Delhi Dated 14.08.2022 For Ay. 2020-21. 2. At The Outset, The Ld. Ar Of The Assessee Brought To Our Notice That This Is A Peculiar Case Wherein The Assessee Had Filed An Appeal Before The Ld. Cit(A)/Nfac Against Order/Intimation Passed By Cpc, Bangalore U/S 143(1) Of The Income Tax Act, 1961 (Hereinafter “The Act”). 3 The Cpc Vide Intimation Dated 23.12.2021 Assessed Total Income Of Assessee At Rs.9,63,080/- Whereas The Assessee Had Returned An Income To The Tune Of Rs.4,05,130/-. Against This Intimation Dated 23.12.2021, The Assessee Filed An Appeal Before The Ld. Cit(A)/Nfac On 19.01.2022; & When The Appeal Was Pending Before The Ld.

For Appellant: Shri Hitesh TrivediFor Respondent: Shri Vaibhav Jain
Section 143(1)Section 154

Aditya Futuristic Trading Pvt. Ltd., Patna vs. CIT-I, Patna

In the result, the appeal of the assessee is dismissed

ITA 184/PAT/2018[2013-14]Status: DisposedITAT Patna22 Dec 2022AY 2013-14

Bench: Shri Sonjoy Sarma, Hon’Ble & Shri Girish Agrawal, Hon’Bleassessment Year: 2013-14 M/S. Aditya Futuristic Trading Cit-1, Patna Pvt. Ltd. C/O. Nirmal & Associates, Chartered Accountants, Nepali Vs. Kothi, Opp. Gasoline Petrol Pump. Boring Road, Patna – 800001. [Pan: Aaeca 9085 E] (Appellant) (Respondent) Present For: Assessee By : Shri Nishant Maitin, Ca Revenue By : Smt. Rinku Singh, Cit/Dr Date Of Hearing : 13.12.2022 Date Of Pronouncement : 22.12.2022 O R D E R Per Sonjoy Sarma, Jm: This Is An Appeal Preferred By The Assessee Against The Order Of Ld. Pcit-1, Patna Dated 23.03.2018 U/S 263 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). The Assessee Has Taken The Following Grounds Of Appeal: “I. For That The Grounds Hereto Are Without Prejudice To Each Other. Ii. For That The Order Passed By Ld. Commissioner Of Income-Tax-1, Patna Is Bad Both In Law & On Facts. Iii. For That The Order Passed By Ld. Commissioner Of Income-Tax-1, Patna Is Based On Presumption, Surmise & Conjectures. Iv. For That The Ld. Commissioner Of Income-Tax-1, Patna Passed The Order Ignoring The Fact That All The Points Which Were Raised In The Notice Had Duly Been Examined By The Ld. Ao.

For Appellant: Shri Nishant Maitin, CAFor Respondent: Smt. Rinku Singh, CIT/DR
Section 143(1)Section 143(2)Section 143(3)Section 263

Anugraha Fashion Mill Private Limited, Tirupur vs. DCIT, CPC, Bangalore

In the result, appeal in I

ITA 883/CHNY/2020[2017-18]Status: DisposedITAT Chennai21 Dec 2022AY 2017-18

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./ I.T.A. Nos.883 & 865/Chny/2020 िनधा"रण वष"/Assessment Years: 2017-18 M/S. Anugraha Fashion Mill Vs. The Deputy Commissioner Of Private Limited, 15, Suriyan Nagar, Income Tax, Abt Rod New Extn., Karuvampalayam, Centralized Processing Centre, Tirupur 641 604. Bangalore 650 500. [Pan:Aahca3311Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Yeshwanth Kumar, Ca ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 12.12.2022 घोषणा की तारीख /Date Of Pronouncement : 21.12.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 3, Coimbatore Dated 31.08.2020 & 28.09.2020 Relevant To The Assessment Year 2017-18. I.T.A. No. 883/Chny/2020 2. The Appellate Order Passed By The Ld. Cit(A) Under Section 250 Of The Income Tax Act, 1961 [“Act”] Dated 31.08.2020 Has Not Been Digitally Signed & Thereby There Was A Mistake Apparent On Record. The Above

For Appellant: Shri Yeshwanth Kumar, CAFor Respondent: Shri AR V Sreenivasan, Addl. CIT
Section 143(1)Section 143(3)Section 154Section 250Section 80I

Anugraha Fashion Mill Private Limited, Tirupur vs. DCIT, CPC, Bangalore

In the result, appeal in I

ITA 865/CHNY/2020[2017-18]Status: DisposedITAT Chennai21 Dec 2022AY 2017-18

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./ I.T.A. Nos.883 & 865/Chny/2020 िनधा"रण वष"/Assessment Years: 2017-18 M/S. Anugraha Fashion Mill Vs. The Deputy Commissioner Of Private Limited, 15, Suriyan Nagar, Income Tax, Abt Rod New Extn., Karuvampalayam, Centralized Processing Centre, Tirupur 641 604. Bangalore 650 500. [Pan:Aahca3311Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Yeshwanth Kumar, Ca ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 12.12.2022 घोषणा की तारीख /Date Of Pronouncement : 21.12.2022 आदेश /O R D E R Per V. Durga Rao: Both The Appeals Filed By The Assessee Are Directed Against Different Orders Of The Ld. Commissioner Of Income Tax (Appeals) 3, Coimbatore Dated 31.08.2020 & 28.09.2020 Relevant To The Assessment Year 2017-18. I.T.A. No. 883/Chny/2020 2. The Appellate Order Passed By The Ld. Cit(A) Under Section 250 Of The Income Tax Act, 1961 [“Act”] Dated 31.08.2020 Has Not Been Digitally Signed & Thereby There Was A Mistake Apparent On Record. The Above

For Appellant: Shri Yeshwanth Kumar, CAFor Respondent: Shri AR V Sreenivasan, Addl. CIT
Section 143(1)Section 143(3)Section 154Section 250Section 80I