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)

Shree Tardeo Jain Swetamber Murti Pujak, Mumbai vs. Income Tax Officer, Exemption Ward 2(3), Mumbai

In the result, the appeal of the assessee bearing ITA No

ITA 5923/MUM/2025[2018-19]Status: DisposedITAT Mumbai07 Apr 2026AY 2018-19

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankarshree Tardeo Jain Swetamber Vs Income Tax Officer (E) Ward 2(3), Murti Pujak Sangh Mumbai 8/E/72, Sonawwala Building, Income Tax Appellate Tribunal, Tardeo, Mumbai-400007 Marine Lines, Mumbai-400020 Pan:Aaets6368M Appellant Respondent Assessee By : Shri Dharan Gandhi & Vinita Nara Respondent By : Shri Priyanka Mashilkar (Sr.Ar) Date Of Hearing : 25/03/2026 Date Of Pronouncement : 07/04/2026 O R D E R Per: Anikesh Banerjee (Jm): The Instant Appeal Of The Assessee Filed Against The Order Of The Nfac, Delhi [For Brevity The “Ld. Cit(A)”], Order Passed Under Section 250 Of The Income Tax Act 1961 (For Brevity ‘The Act’) For Assessment Year 2018-19, Date Of Order 21.07.2025. The Impugned Order Emanated From The Order Of The National E- Assessment Centre, Delhi (For Brevity The ‘Ld. Ao’) Order Passed Under Section 143(3) R.W.S. 144B Of The Act Date Of Order 19.04.2021. 2 Shree Tardeo Jain Swetamber Murti Pujak Sangh 2. The Brief Facts Of The Case Are That The Assessee Is A Trust & During The Assessment Year The Assessee Filed The Return Along With Form No.10. Since The Assessee Is Registered Trust & Eligible For Deduction U/Sec. 11 Of The Act The Computation Of Income Available For Accumulation Is As Follows: Sr. No. Particulars Amount(Rs.) A. Gross Receipts 94,21,849/- B. Less: 15% Benefit U/Sec. 11(1)(A) (14,13,277/-) C. Less: Application Of Income For Purpose Of (29,43,668/-) Trust(Accepted By Ld. Ao) D. Net Receipt Available For Accumulation 50,64,903/-

For Appellant: Shri Dharan Gandhi & Vinita NaraFor Respondent: Shri Priyanka Mashilkar (Sr.AR)
Section 11Section 11(1)(a)Section 11(2)Section 11(5)Section 12ASection 143(3)Section 250

Xchanging Solutions Limited (Formerly Known As Cambridge Solutions Limited), Bangalore vs. The Deputy Commissioner of Income Tax, Circle 7(1)(1), Bangalore

In the result appeal filed by the assessee is partly allowed

ITA 385/BANG/2025[2011-12]Status: DisposedITAT Bangalore06 Apr 2026AY 2011-12

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year 2011-12 M/S. Xchanging Solutions Limited Vs. (Formerly Known As Cambridge Solutions Limited), Xchanging Tower, 39/40, Digital Park, Hp Avenue, The Deputy Commissioner Of Income Tax Electronic City, Hosur Main Road, Circle – 7(1)(1), Electronic City S.O., Bangalore. Konapanna Agrahara, Bangalore – 560 100 Pan: Aafcs9303L Appellant Respondent Appellant By : Shri Padamchand Kincha, Ca Respondent By : Dr. Divya K. J – Citdr Date Of Hearing : 13.01.2026 Date Of Pronouncement : 06.04.2026 O R D E R Per Prashant Maharishi1. This Appeal Is Filed For Assessment Year 2011 – 12 Against The Assessment Order Passed By The Deputy Commissioner Of Income Tax, Circle 7 (1) (1), Bangalore (The Learned Ao) Passed In Pursuance Of Direction Of The Learned Dispute Resolution Panel'S Wherein The Income Tax Appellate Tribunal Vide Its Order Dated 19 January 2022 In Ita A No. 492/Bangalore/2015 & Subsequent Miscellaneous Application No. 61/Bangalore/2022 Dated 26/8/2022 Was Passed. 2. Over & Above The Several Grounds Raised By The Assessee The Main Contention Is That The Order Passed By The Learned Assessing Officer On 27 December 2024 Is Invalid. Page 2 Of 11 3. Brief Facts Of The Case Shows That The Assessee Company Filed Its Return Of Income At The Total Income Of Rs. Nil. The Case Was Selected For Scrutiny Which Resulted Into The Final Assessment Order Passed Under Section 143 (3) Read With Section 144C (13) Of The Income Tax Act, 1961 (The Act) Determining The Assessed Income At ₹ 190,805,854/–.

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Dr. Divya K. J – CITDR
Section 143Section 144CSection 254Section 92C

Klg Jewellers, Patiala vs. The Assistant Commissioner of Income Tax Central Circle-2, Chandigarh

ITA 1236/CHANDI/2025[2020-2021]Status: DisposedITAT Chandigarh06 Apr 2026AY 2020-2021

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am आयकरअपीलसं./ Ita No.1236/Chandi/2025 (िनधा"रणवष" / Assessment Year: 2020-21) M/S Klg Jewellers Acit Central Circle-2 बनाम/ Vs. Showroom No.6, Bhupindra Road Chandigarh Patiala – 147001 "ायीलेखासं./जीआइआरसं./Pan/Gir No. Aanfk-1785-F (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Sudhir Sehgal (Advocate) – Ld. Ar ""थ"कीओरसे/Respondent By : Sh. Manav Bansal (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 25-03-2026 घोषणाकीतारीख /Date Of Pronouncement : 06-04-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. Aforesaid Appeal By Assessee For Assessment Year (Ay) 2020-21 Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals)-3, Gurgaon [Cit(A)] Dated 27-08-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 153A R.W.S. 143(3) Of The Act On 31-03-2022. The Only Prayer Made By Ld. Ar Is Reasonable Estimation Of Gross Profit Rate As Applied By Ld. Cit(A) Whereas Ld. Cit-Dr Has Pleaded For Dismissal Of The Appeal. Having Heard Rival Submissions & Upon Perusal Of Case Records, Our

For Appellant: Sh. Sudhir Sehgal (Advocate) – Ld. ARFor Respondent: Sh. Manav Bansal (CIT) - Ld. DR
Section 132Section 153A