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)

Bantra Anath Bandu Samity, Howrah vs. Asst Director of Income Tax, CPC, Bangalore

In the result, the appeal of the assessee is treated as allowed for statistical purposes

ITA 385/KOL/2021[2019-20]Status: HeardITAT Kolkata02 Feb 2022AY 2019-20

Bench: Shri Sanjay Gargi.T.A. No.385/Kol/2021 Assessment Year: 2019-20 Bantra Anath Bandu Samity.….……..............………………..……Appellant 31/16, Brindaban Mullick Lane, Kadamtala, Howrah-711101. [Pan: Aabtb6890N] Vs. Acit, Cpc……………..…….…..………………...…………..…..Respondent Appearances By: Shri S. K. Tulsiyan, Advocate, Appeared On Behalf Of The Appellant. Shri Gautam Mondal, Addl. Cit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : February 02, 2022 Date Of Pronouncing The Order : February 02, 2022 Hearing Through Video Conferencing Order The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 09.06.2021 Of The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Assessee In This Appeal Has Taken The Following Grounds Of Appeal: “1. That, On The Facts & In The Circumstances Of The Case & In Law, The Order Passed By The Ld. Cit(A) U/S 250 Of The Act Dated 09.06.2021 Rejecting The Claim Of The Assessee Without Properly Appreciating The Explanation & Evidences Filed Is Arbitrary, Erroneous, Without Proper Reasons & Hence Unsustainable In Law. 2. That, The Ld. Cit(A) Erred In Disallowing/Adding Back Sum Of Rs.9,03, 1 57/- For Non Submission Of Audit Report In Form 10Bb Within The Stipulated Period. 3. That, The Ld. Cit(A) Erred In Rejecting The Reason & Explanation Furnished By The Assessee For Delay In Submitting Audit Report In Form 10Bbb 4. That, The Appellant Craves Leave To Amend, Alter, Modify, Substitute, Add To, Abridge And/ Or Rescind Any Or All Of The Above Grounds.”

Section 143(1)Section 250

Transsys Solutions Pvt Ltd, Kodambakkam vs. CIT(A), NFAC, Delhi

In the result, the appeal filed by the assessee is allowed

ITA 489/CHNY/2021[2019-20]Status: DisposedITAT Chennai31 Jan 2022AY 2019-20

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.489/Chny/2021 िनधा"रण वष"/Assessment Year: 2019-20 M/S. Transsys Solutions Pvt. Ltd., The Assistant Director Of Plot. Super A 16-17, Rr Towers, Tvk Vs. Income Tax, Industrial Estate, Guindy, Cpc, Bengaluru 560 500. Chennai 600 032. [Pan:Aadct4603N] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Pawan Bohra, C.A. ""थ" की ओर से/Respondent By : Shri Ar V Sreenivasan, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 25.01.2022 घोषणा की तारीख /Date Of Pronouncement : 31.01.2022 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), New Delhi Dated 21.09.2021 Relevant To The Assessment Year 2019-20. 2. Brief Facts Of The Case Are That The Assessee Filed Its Return Of Income For The Assessment Year 2019-20 On 25.10.2019. The Cpc, Bengaluru Has Completed The Assessment Under Section 143(1) Of The Income Tax Act

For Appellant: Shri Pawan Bohra, C.AFor Respondent: Shri AR V Sreenivasan, Addl. CIT
Section 139(1)Section 143(1)Section 36Section 36(1)(va)Section 43BSection 44A

Sophia Automotive Pvt Ltd, Chennai vs. ITO, Corp Ward -6(3), Chennai

In the result, the appeal filed by the assessee in I

ITA 322/CHNY/2019[2012-13]Status: DisposedITAT Chennai31 Jan 2022AY 2012-13

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.322/Chny/2019 & 3383/Chnyh/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2011-12 M/S. Sophia Automotive Private The Income Tax Officer, Limited, No. 2F(Np), Sidco Industrial Vs. Corporate Ward 6(3), Estate, Ambattur, Chennai 600 098. Chennai 34. [Pan:Aaics6884P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 25.01.2022 घोषणा की तारीख /Date Of Pronouncement : 31.01.2022 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) 16, Chennai Dated 30.11.2018 Relevant To The Assessment Year 2012-13 & Order Dated 19.09.2018 For The Assessment Year 2011-12. 2. When The Appeal In I.T.A. No. 322/Chny/2019 For The Assessment Year 2012-13 Was Taken Up For Hearing, The Ld. Counsel For The Assessee Has Submitted That The Appeal Filed Before The Ld. Cit(A) Was Dismissed On The Ground That The Delay In Filing The Appeal Before The 2

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri G. Johnson, Addl. CIT
Section 143(1)Section 143(3)Section 147Section 148

Sophia Automotive Pvt Ltd, Chennai vs. ITO, Corp Ward -6(3), Chennai

In the result, the appeal filed by the assessee in I

ITA 3383/CHNY/2018[2011-12]Status: DisposedITAT Chennai31 Jan 2022AY 2011-12

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.322/Chny/2019 & 3383/Chnyh/2018 िनधा"रण वष"/Assessment Years: 2012-13 & 2011-12 M/S. Sophia Automotive Private The Income Tax Officer, Limited, No. 2F(Np), Sidco Industrial Vs. Corporate Ward 6(3), Estate, Ambattur, Chennai 600 098. Chennai 34. [Pan:Aaics6884P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri D. Anand, Advocate ""थ" की ओर से/Respondent By : Shri G. Johnson, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 25.01.2022 घोषणा की तारीख /Date Of Pronouncement : 31.01.2022 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) 16, Chennai Dated 30.11.2018 Relevant To The Assessment Year 2012-13 & Order Dated 19.09.2018 For The Assessment Year 2011-12. 2. When The Appeal In I.T.A. No. 322/Chny/2019 For The Assessment Year 2012-13 Was Taken Up For Hearing, The Ld. Counsel For The Assessee Has Submitted That The Appeal Filed Before The Ld. Cit(A) Was Dismissed On The Ground That The Delay In Filing The Appeal Before The 2

For Appellant: Shri D. Anand, AdvocateFor Respondent: Shri G. Johnson, Addl. CIT
Section 143(1)Section 143(3)Section 147Section 148