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)

Income Tax Officer, Faridabad vs. Manav Sanskar Shiksha Sanstha, Faridabad

In the result, appeal of the Revenue is partly allowed

ITA 3190/DEL/2025[2020]Status: DisposedITAT Delhi17 Jun 2026

Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Assessment Year : 2020-21] Ito Vs Manav Sanskar Shiksha Aaykar Bhawan, Sanstha, 3 & 4, Ashoka Enclave, Faridabad Part-1, Sector-4, Faridabad, Haryana-121001 Haryana-201004 Pan-Aacam0915H Appellant Respondent Revenue By Shri Om Prakash, Sr. Dr Assessee By Shri Ajay Kumar Agarwal, Ca Date Of Hearing 24.03.2026 Date Of Pronouncement 17.06.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Revenue Against The Order Dated 21.03.2025 By Ld. Commissioner Of Income Tax (A), National Faceless Appeal Centre (“Nfac”), Delhi [“Ld. Cit(A)”] In Appeal No. Nfac/2019-20/10434387 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Intimation Order Dated 24.12.2021 Passed U/S 143(1) Of The Act Pertaining To Assessment Year 2020-21. 2. Brief Facts Of The Case Are That The Assessee Is A Registered Society, Doing Charitable Activity Of Imparting Education & Registered U/S 12Aa Of The Act In Terms Of Approval Granted By Ld. Cit(A), Faridabad Dt 15.04.2013 & Subsequently, Renewed By Pcit Vide Order Dated 08.07.2024. The Return Of Income For The Year Under Appeal Was Filed In Form Itr 7 On 27.12.2020 Loss Of 13,76,228/- Being Excess Of Expenditure Over Income & Has Not Exemption U/S 12 Of The Act. The Cpc In Terms Of The Order U/S 143(1) Of The Act Denied The Exemption As The Assessee Has Not Filed Form 10B Alongwith The Return Of Income Filed & Create A Demand On Gross Receipts. Thereafter, The Assessee A Rectification Application However, As The Assessee Has Not Filed Form 10B Before The Filing Of Return Of Income & Power Of Condonation Of Delay In From 10B As Per Section 119(2)(B) Of The Act Is With The Concerned Pcit/Cit/Dit Therefore, The Cpc Has Rejected The Application Of The Assessee Filed U/S 154 Of The Act.

Section 11Section 119(2)(b)Section 12Section 12ASection 12A(1)(b)Section 143(1)Section 154Section 250

Veenaben Arvindbhai Shah, Ahmedabad vs. CPC, Bengaluru Juris. AO-the ITO, Ward-1(3)(1), Petlad

In the result, the appeal of the assessee is allowed

ITA 2430/AHD/2025[2024-25]Status: DisposedITAT Ahmedabad16 Jun 2026AY 2024-25

Bench: Ms. Suchitra Kamblemrs. Veenaben Arvindbhai Shah, Centralised Processing Center, Mig-1/Y/1302, Ghb Flat, Income Tax Department, Bengaluru, Shastrinagar Char Rasta, [Jurisdiction Ao – Income Tax Nr. Anmol Tower, Shastrinagar, Officer, Ward 1(3)(1), Petland], Naranpura, Ahmedabad Vs. T.P. No.2, F.P. No.24, Bank House, Gujarat Nr. Laxmiji Temple, Ranchodji College Road, Petland, Anand, Gujarat Pan: Mtxps4808J (Appellant) : (Respondent) : Shri Kushal Fofaria, Ar Assessee By Respondent By : Shri Girish Parihar, Sr. Dr Date Of Hearing : 01.04.2026 : 16.06.2026 Date Of Pronouncement O R D E R Per : Suchitra Kamble, J M: The Appeal Filed By The Assessee Is Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), Addl/Jcit(A)[In Short “Cit(A)”], Raipur Dated 27.11.2025 For The Assessment Year (In Short “Ay”) 2024-25. 2. The Assessee Has Raised The Following Grounds Of Appeal: “1. The Ld. Cit(A) Has Erred In Law & On Facts Of The Case In Upholding Prima Facie Adjustment U/S. 143(1) Of The Act Made By Cpc In Respect Of Rebate Claimed U/S. 87A Of The Act Which Is A Debatable & Contentious Issue Requiring Long Drawn Process Of Reasoning. 2. The Ld. Cit(A) Has Erred In Law & On Facts Of The Case In Confirming Denial Of Rebate Of Rs. 24,583/-Claimed U/S. 87A Of The Act In Respect Of Tax Payable U/S. 112 Of The Act On Long Term Capital Gain Earned On Sale Of Residential Flat. Mrs. Veenaben Arvindbhai Shah

For Respondent: Shri Girish Parihar, Sr. DR
Section 112Section 112ASection 112A(6)Section 115BSection 143(1)Section 2Section 87A