Section 143(2) of the Income Tax Act

Income-tax Act, 2025: s.270

Section 143(2) 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(2) is National Thermal Power Co. Ltd. v. CIT (229 ITR 383), cited in 5,834 of the 13,613 judgments on BharatTax that turn on this section.

Leading authorities on Section 143(2)

National Thermal Power Co. Ltd. v. CIT
229 ITR 383 · 1998 · Supreme Court
5,834
citing judgments

Appellate authorities can consider new claims and additional grounds if the relevant facts are already on record. The purpose of assessment is to correctly determine tax liability, allowing both parties to raise issues.

CIT v. Kabul Chawla
380 ITR 573 · 2016 · High Court
3,235
citing judgments

In a search assessment under Section 153A, additions can only be made for completed or non-abated assessment years if incriminating material relevant to those years is found during the search, although notice under Section 153A(1) is mandatorily issued for six assessment years preceding the search.

Malabar Industrial Co. Ltd. v. CIT
243 ITR 83 · 2000 · Supreme Court
2,943
citing judgments

For revision under Section 263, the Assessing Officer's order must be both erroneous and prejudicial to the interests of the revenue; if either condition is not met, the revisionary jurisdiction cannot be invoked. An order is not erroneous merely because the Assessing Officer did not record the details of enquiries conducted, provided due enquiries were made.

CIT v. Reliance Utilities & Power Ltd.
313 ITR 340 · 2009 · High Court
2,118
citing judgments

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such investments.

Radhasoami Satsang v. CIT
193 ITR 321 · 1992 · Supreme Court
1,695
citing judgments

The principle of consistency applies in tax matters, meaning a fundamental aspect found to be true in one assessment year should not be changed in a subsequent year if the order was not challenged.

CIT v. Kelvinator of India Ltd.
320 ITR 561 · 2010 · Supreme Court
1,673
citing judgments

An Assessing Officer cannot initiate reassessment proceedings under Section 147 of the Income Tax Act based on a mere change of opinion. Reassessment is permissible only when there is fresh tangible material leading to the belief of income escapement, not merely a review of existing facts.

Maxopp Investment Ltd. v. CIT
402 ITR 640 · 2018 · Supreme Court
1,596
citing judgments

Disallowance under Section 14A is not automatic and requires the Assessing Officer to record satisfaction before applying Rule 8D. Only investments yielding exempt income are considered for disallowance, irrespective of their strategic nature.

Cheminvest Ltd. v. CIT
378 ITR 33 · 2015 · High Court
1,569
citing judgments

A disallowance under Section 14A of the Income-tax Act, 1961, for expenditure incurred in relation to exempt income cannot be made if the assessee has not earned any exempt income during the relevant previous year.

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).

CIT v. Simit P. Sheth
356 ITR 451 · 2013 · High Court
1,465
citing judgments

Additions for alleged bogus purchases should be restricted to the profit element, not the entire turnover. The profit element is often estimated at 12.5% of the purported bogus purchases.

Judgments on Section 143(2)

Bharat Kumar Bansal, Hyderabad vs. ACIT., Central Circle-2(1), Hyderabad

In the result, all the appeals filed by the assessee are allowed

ITA 1004/HYD/2025[2017-18]Status: DisposedITAT Hyderabad07 Jan 2026AY 2017-18

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1000 To 1006/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2013-14 To 2019-20) Shri Bharat Kumar Bansal Vs. Assistant Commissioner Hyderabad Of Income Tax Pan:Abfpb6416P Central Circle 2(1) Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A Srinivas, Ca राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 17/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026 आदेश/Order Per Bench: These Seven Appeals Are Filed By Shri Bharat Kumar Bansal (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) All Dated 07.03.2025 For The A.Ys. 2013- 14 To 2019-20. Since Common & Identical Issues Are Raised By The Assessee In All These Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find There Is A Delay Of 06 Days In Filing Of All These Appeals Before This Tribunal. The Assessee Has Page 1 Of 9

For Appellant: Shri A Srinivas, CAFor Respondent: : Shri S. Arun Kumar, Sr. DR
Section 153C

Bharat Kumar Bansal, Hyderabad vs. ACIT, Central Circle-2(1), Hyderabad

In the result, all the appeals filed by the assessee are allowed

ITA 1003/HYD/2025[2016-17]Status: DisposedITAT Hyderabad07 Jan 2026AY 2016-17

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1000 To 1006/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2013-14 To 2019-20) Shri Bharat Kumar Bansal Vs. Assistant Commissioner Hyderabad Of Income Tax Pan:Abfpb6416P Central Circle 2(1) Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A Srinivas, Ca राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 17/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026 आदेश/Order Per Bench: These Seven Appeals Are Filed By Shri Bharat Kumar Bansal (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) All Dated 07.03.2025 For The A.Ys. 2013- 14 To 2019-20. Since Common & Identical Issues Are Raised By The Assessee In All These Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find There Is A Delay Of 06 Days In Filing Of All These Appeals Before This Tribunal. The Assessee Has Page 1 Of 9

For Appellant: Shri A Srinivas, CAFor Respondent: : Shri S. Arun Kumar, Sr. DR
Section 153C

Bharat Kumar Bansal, Hyderabad vs. ACIT, Central Circle-2(1), Hyderabad

In the result, all the appeals filed by the assessee are allowed

ITA 1002/HYD/2025[2015-16]Status: DisposedITAT Hyderabad07 Jan 2026AY 2015-16

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1000 To 1006/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2013-14 To 2019-20) Shri Bharat Kumar Bansal Vs. Assistant Commissioner Hyderabad Of Income Tax Pan:Abfpb6416P Central Circle 2(1) Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A Srinivas, Ca राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 17/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026 आदेश/Order Per Bench: These Seven Appeals Are Filed By Shri Bharat Kumar Bansal (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) All Dated 07.03.2025 For The A.Ys. 2013- 14 To 2019-20. Since Common & Identical Issues Are Raised By The Assessee In All These Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find There Is A Delay Of 06 Days In Filing Of All These Appeals Before This Tribunal. The Assessee Has Page 1 Of 9

For Appellant: Shri A Srinivas, CAFor Respondent: : Shri S. Arun Kumar, Sr. DR
Section 153C

Bharat Kumar Bansal, Hyderabad vs. ACIT., Central Circle -2(1), Hyderabad

In the result, all the appeals filed by the assessee are

ITA 1001/HYD/2025[2014-15]Status: DisposedITAT Hyderabad07 Jan 2026AY 2014-15

Bench: Shri Ravish Sood & Shri Madhusudan Sawdiaआ.अपी.सं / Ita Nos.1000 To 1006/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2013-14 To 2019-20) Shri Bharat Kumar Bansal Vs. Hyderabad Pan:Abfpb6416P (Appellant) Assistant Commissioner Of Income Tax Central Circle 2(1) Hyderabad (Respondent) निर्धारिती द्वारा /Assessee By: Shri A Srinivas, Ca राजस्व द्वारा / Revenue By:: | Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख /Date Of Hearing: 17/12/2025 घोषणा की तारीख / Pronouncement: | 07/01/2026 आदेश/Order Per Bench: These Seven Appeals Are Filed By Shri Bharat Kumar Bansal (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) All Dated 07.03.2025 For The A.Ys. 2013- 14 To 2019-20. Since Common & Identical Issues Are Raised By The Assessee In All These Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find There Is A Delay Of 06 Days In Filing Of All These Appeals Before This Tribunal. The Assessee Has Filed Separate Petitions For Condonation Of Delay Along With Copies Of The Affidavits Explaining The Reasons For Such Delay & Praying For Condonation Of The Same. After Considering The Reasons Stated By The Assessee & Upon Hearing The Submissions Of The Learned Departmental Representative (“Ld. Dr”), We Are Satisfied That The Delay Was Due To Reasonable Cause. Accordingly, The Delay Of 06 Days In Filing Of All These Appeals Are Condoned & The Appeals Are Admitted For Adjudication On Merits. 3. Identical Grounds Have Been Raised By The Assessee In

For Appellant: Shri A Srinivas, CA
Section 153C

Bharat Kumar Bansal, Hyderabad vs. ACIT, Central Circle-2(1), Hyderabad

In the result, all the appeals filed by the assessee are allowed

ITA 1000/HYD/2025[2013-14]Status: DisposedITAT Hyderabad07 Jan 2026AY 2013-14

Bench: Shri Ravish Sooda N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1000 To 1006/Hyd/2025 (िनधा"रण वष"/Assessment Years: 2013-14 To 2019-20) Shri Bharat Kumar Bansal Vs. Assistant Commissioner Hyderabad Of Income Tax Pan:Abfpb6416P Central Circle 2(1) Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri A Srinivas, Ca राज" व "ारा/Revenue By:: Shri S. Arun Kumar, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 17/12/2025 घोषणा की तारीख/Pronouncement: 07/01/2026 आदेश/Order Per Bench: These Seven Appeals Are Filed By Shri Bharat Kumar Bansal (“The Assessee”), Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) All Dated 07.03.2025 For The A.Ys. 2013- 14 To 2019-20. Since Common & Identical Issues Are Raised By The Assessee In All These Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Consolidated Order. 2. At The Outset, We Find There Is A Delay Of 06 Days In Filing Of All These Appeals Before This Tribunal. The Assessee Has Page 1 Of 9

For Appellant: Shri A Srinivas, CAFor Respondent: : Shri S. Arun Kumar, Sr. DR
Section 153C

Income Tax Officer, Ranchi, Jharkhand vs. Amba Carbonisation Pvt. Ltd., Ranchi, Jharkhand

In the result, the appeal of the revenue is dismissed

ITA 61/RAN/2024[2013-14]Status: DisposedITAT Ranchi06 Jan 2026AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Ratnesh Nandan Sahayi.T.A. No.61/Ran/2024 Assessment Year: 2013-14 Ito, Ranchi………..…………….…….…...................................……….……Appellant Vs. Amba Carbonisation Pvt. Ltd ……....….…..….........……........……...…..…..Respondent 21, Ashok Bhawan, Kali Asthan Road, Ranchi, Jharkhand. [Pan: Aadca7460J] Appearances By: Shri Kanhaiya Lal Kanak, Cit, Appeared On Behalf Of The Appellant. Shri Devesh Poddar, Ar, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 18, 2025 Date Of Pronouncing The Order : January 06, 2026 Order Per Sonjoy Sarma: This Appeal Filed By The Revenue Is Directed Against The Order Of The Nfac, Delhi (Hereinafter Referred To As “Ld. Cit(A)”) Dated 15.01.2024 Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As The “Act”). 2. Brief Facts Of The Case Are That The Assessee Is A Company Incorporated Under The Provisions Of The Companies Act & Is Engaged In The Business Of Manufacturing & Trading Of Special Smokeless Coal/Coke. The Assessee Also Derives Income By Way Of Interest On Bank Deposits. As Per Information Available With The Income-Tax Department, It Was Noticed That The Assessee’S Bank Accounts Reflected Substantial Cash Deposits, Which Were Allegedly Withdrawn Immediately Through Rtgs/Neft Transactions. It Was Further Observed That There Existed A Difference Between The Turnover Disclosed By The Assessee In The Return Of Income & The Total Credits Appearing In The Bank Accounts. On The Basis Of The Above Information, The Assessing Officer (Ao) Initiated Reassessment Proceedings By Issuing A Notice Under Section 148 Of The

Section 139Section 142(1)Section 143(2)Section 143(3)Section 144BSection 147Section 148Section 250Section 270ASection 273B