Section 143(3) of the Income Tax Act

Income-tax Act, 2025: s.270

Section 143(3) 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(3) is National Thermal Power Co. Ltd. v. CIT (229 ITR 383), cited in 5,834 of the 75,154 judgments on BharatTax that turn on this section.

Leading authorities on Section 143(3)

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.

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.

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. Vegetable Products Ltd.
88 ITR 192 · 1973 · Supreme Court
2,664
citing judgments

When two equally plausible interpretations of a taxing provision are possible, or when conflicting views exist from non-jurisdictional High Courts, the interpretation that favors the assessee must be adopted.

CIT v. Manjunatha Cotton & Ginning Factory
359 ITR 565 · 2013 · High Court
2,590
citing judgments

A penalty notice issued under section 274 read with section 271(1)(c) is invalid if it fails to specify whether the penalty proceedings are initiated for concealment of income or for furnishing inaccurate particulars of income. This non-specification vitiates the penalty proceedings.

Pr. CIT v. Abhisar Buildwell (P.) Ltd.
149 Taxmann.com 399 · 2023 · Supreme Court
2,379
citing judgments

An assessment under section 153A is without jurisdiction if there is an absence of incriminating material for an unabated assessment year.

CIT v. Multiplan India Ltd.
38 ITD 320 · 1991 · ITAT
2,267
citing judgments

An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

CIT v. Reliance Petroproducts Pvt. Ltd.
322 ITR 158 · 2010 · Supreme Court
2,228
citing judgments

Penalty under Section 271(1)(c) for furnishing inaccurate particulars or concealment of income is not automatically leviable if the assessee has made a full disclosure of all particulars and the addition or disallowance arises from a difference of opinion.

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.

Judgments on Section 143(3)

Raj Ranga Textiles Private Limited, Coimbatore vs. The Assistant Commissioner, Coimbatore

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

ITA 2667/CHNY/2025[2017-2018]Status: DisposedITAT Chennai03 Jun 2026AY 2017-2018

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं/.Ita No.2667/Chny/2025 (ननिाारण वर्ा / Assessment Year: 2017-18 Raj Ranga Textiles Pvt. Ltd., The Assistant Commissioner Of Sf No.821/2, Kallipalayam Vs. Income-Tax, Chikkarampalayam Post Corporate Circle-1 Karamadai, Coimbatore. Coimbatore- 641 104 [Pan: Aabcr-8500-N] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By : Shri. N. Maruthachalamoorthy, C.A प्रत्यर्थी की ओर से/Respondent By : Ms.Gouthami Manivasagam, Addl.Cit सुनवाई की तारीख/Date Of Hearing : 16.04.2026 घोर्णा की तारीख/Date Of Pronouncement : 03.06.2026 आदेश/ O R D E R Per S. R. Raghunatha, Am : This Appeal By The Assessee Is Arising Out Of The Order Dated 15.04.2025, Passed By The Learned Commissioner Of Income Tax (Appeal), Nfac, Delhi (In Short “Ld.Cit(A)”) For The Assessment Year (A.Y) 2017-18 Against The Assessment Order U/S.143(3) Of The Income Tax Act, 1961 (Hereinafter The ‘Act’) Passed By The Ao, Dated 24.12.2019. :-2-: Ita. No.2667/Chny/2025

For Appellant: Shri. N. Maruthachalamoorthy, C.AFor Respondent: Ms.Gouthami Manivasagam, Addl.CIT
Section 115JSection 143(3)Section 40A(3)Section 68

Gokuladoss Sathish Kumar, Cuddalore vs. ITO, Ward-5, Cuddalore

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

ITA 2278/CHNY/2025[2017-18]Status: DisposedITAT Chennai03 Jun 2026AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunathaआयकर अपील सं./Ita No. 2278/Chny/2025 ननिाारण वर्ा / Assessment Year: 2017-18 Gokuladoss Sathish Kumar The Income Tax Officer 48, Main Road, Mangalampet Vs. Ward - 5 Cuddalore – 606 104. Cuddalore. [Pan: Acsps2887D] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. R.Viswanathan, Ca प्रत्यर्थी की ओर से/Respondent By : Ms.T.Mythili, Jcit सुनवाई की तारीख/Date Of Hearing : 12.03.2026 घोर्णा की तारीख/Date Of Pronouncement : 03.06.2026 आदेश /O R D E R Per S. R. Raghunatha, Am : This Appeal Of The Assessee Is Filed Against The Order Of The Learned Commissioner Of Income Tax (Appeal), Nfac, Delhi (In Short ‘Ld.Cit(A)’) For The Assessment Year 2017-18, Vide The Order Dated 11.07.2025 Against The Order Passed By The Income Tax Officer, Ward 5, Cuddalore, (In Shot “Ao”) U/S.143(3) Of The Income Tax Act, 1961 (In Short ‘The Act’) Dated 31.12.2019. 2. The Solitary Raised By The Assessee In His Grounds Of Appeal Is That The Ld.Cit(A) Has Erred In Confirming The Order Of The Assessing Officer, Wherein The Assessment Order Was Passed By The Ao By Rejecting The Cash Book & :-2-: Ita. No:2278/Chny/2025. Treating The Cash Deposits Of Rs.2,18,40,500/- Made During The Demonetisation Period As Unexplained Money U/S.68 Of The Act. The Ao Further Erred In Concluding That The Assessee Had Artificially Inflated Cash Sales During The Period From 01.11.2016 To 08.11.2016 To Accommodate The Deposit Of Specified Bank Notes.

For Appellant: Shri. R.Viswanathan, CAFor Respondent: Ms.T.Mythili, JCIT
Section 143(1)Section 143(2)Section 143(3)Section 68