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)

Shri Sureshkumar Harjivanbhai Chandarana, Rajkot vs. The ACIT, Circle - 2 (2) (1), Rajkot

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

ITA 415/RJT/2023[2016-17]Status: HeardITAT Rajkot15 Dec 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No. 415/Rjt/2023 (िनधा"रण वष"/Assessment Year: (2016-17) Sureshkumar Harjivanbhai Chandarana Acit, Circle – 2(2)(1), Rajkot A-75, New Market Yard, Village-Bedi, Vs. Aayakar Bhavan, Race Course Ring Morbi, Highway, Rajkot- 360 003 Road, Rajkot –360 001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abcpc8536E (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Mehul Ranpura, Ld. Ar Respondent By : Shri Durga Dutt, Ld. Cit(Dr) Date Of Hearing : 27/11/2025 : 15/12/2025 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, Am: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay) 2016-17, Is Directed Against The Order Passed Under Section 250 Of The Income Tax Act, 1961 (Hereinafter Referred To As “The Act”) By Commissioner Of Income-Tax, Appeal Cit(A), Ahmedabad-13 Dated 06.10.2023 [In Short, “Ld. Cit(A)”], Which In Turn Arises Out Of An Order Passed By The Assessing Officer U/S 143(3) R.W.S. 144C(3) Of The Act, Vide Order Dated 19.12.2019. 2. Grounds Of Appeal Raised By The Assessee, Are As Follows:

For Appellant: Shri Mehul Ranpura, Ld. ARFor Respondent: Shri Durga Dutt, Ld. CIT(DR)
Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 250

Avon Cycles Limited, G.T Road, Dhandari Kalan, Ludhiana vs. Pr. Commissioner of Income Tax, 1, Rishi Nagar, Ludhiana

In the result, the appeal of the assessee is partly allowed

ITA 705/CHANDI/2025[2021-22]Status: DisposedITAT Chandigarh15 Dec 2025AY 2021-22

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं/. Ita No. 705/Chd/2025 िनधा"रणवष" / Assessment Year: 2021-22 Avon Cycles Ltd., Vs The Pcit-I, G.T.Road, Dhandari Kalan, Rishi Nagar, Ludhiana. Ludhiana. "थायीलेखासं/.Pan No: Aabca4140R अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Ashish Aggarwal, Ca Revenue By : Shri Manav Bansal, Cit, Dr Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15/12/2025 Physical Hearing Order Per Laliet Kumar, Jm This Appeal Filed By The Assessee Is Directed Against The Order Of The Principal Commissioner Of Income Tax, Ludhiana-1 (Hereinafter Referred To As The "Pcit"), Dated 27.03.2025, Passed Under Section 263 Of The Income Tax Act, 1961 (The "Act") For The Assessment Year 2021-22. 2. The Assessee Has Raised The Following Substantive Grounds Of Appeal: “1. That Ld. Pcit -1, Ludhiana, Erred In Law & On Facts In Assuming The Jurisdiction To Invoke The Provisions Of Section 263 Of The Act To Set Aside The Order Passed By The Assessing Officer (National Faceless Assessment Centre, Delhi) When The Order Was Neither Erroneous Nor Prejudicial To The Interest Of Revenue. The Order Passed By Ld. Pcit(1), Ludhiana, Being Illegal Unjustified & Against The Provisions Of Section 263 May Be Annulled. 2. That Ld. Pcit (1) Erred In Law & On Facts In Setting Aside The Order Of Assessing Officer (National Faceless Assessment Centre, Delhi) By Applying The Different Approach On The Same Set Of Facts On The Issues Already Considered By The Assessing Officer.

For Appellant: Shri Ashish Aggarwal, CAFor Respondent: Shri Manav Bansal, CIT, DR
Section 143(3)Section 194JSection 263Section 69C

Bharati Nimba Patil, Nashik vs. National Faceless Assessment Centre, Delhi

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 503/PUN/2025[2014-15]Status: DisposedITAT Pune15 Dec 2025AY 2014-15

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.503/Pun/2025 िनधा"रण वष" / Assessment Year : 2014-15 Bharati Nimba Patil, Vs. Ito, Nfac, Delhi. S. No.235, P. No.53, 54, Shri Datta Krupa Kalanagar Mhasarul, Behind Aakash Petrol Pump, Nashik- 422004. Pan : Akapp7755P Appellant Respondent Assessee By : Shri Sanket M. Joshi (Virtual) Revenue By : Shri Bharat Andhale (Virtual) Date Of Hearing : 02.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Vinay Bhamore, Jm: This Appeal Filed By The Assessee Is Directed Against The Order Dated 27.09.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Year 2014-15. 2. The Appellant Has Raised The Following Grounds Of Appeal :- “1] The Learned Cit(A) Erred In Dismissing The Appeal In Limine & Thereby Confirming The Addition Of Rs.48,75,000 Made By The A.O. In The Ex-Parte Asst. Order U/S 144 R.Ws. 147 Passed During Covid Period, By Taxing The Entire Consideration Received On Sale Of Agricultural Land As Stcg Without Verifying The Contention Raised In Form 35 That The Impugned Land Was Rural Agricultural

For Appellant: Shri Sanket M. Joshi (Virtual)For Respondent: Shri Bharat Andhale (Virtual)
Section 143(3)Section 144Section 147Section 148Section 2(14)

Shree Bhogawati Sahakari Sakhar Karkhana Ltd, Kolhapur vs. ACIT, Circle-1, Kolhapur

In the result, the appeal of the assessee in ITA

ITA 2198/PUN/2024[2014-15]Status: DisposedITAT Pune15 Dec 2025AY 2014-15

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2194 To 2198/Pun/2024 िनधा"रण वष" / Assessment Years : 2010-11 To 2014-15 Shree Bhogawati Sahakari Vs. Acit, Circle-1, Sakhar Karkhana Ltd., Kolhapur. Shahunagar Parite, Sugar Factory, Shahunagar Parite, Tal- Karveer, Kolhapur- 416211. Pan : Aaaas3731R Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amit Bobde Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2010-11 To 2014-15 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2194/Pun/2024 For A.Y. 2010-11 For Adjudication As The Lead Case.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde
Section 143(1)Section 143(3)Section 250Section 36Section 36(1)

Shree Bhogawati Sahakari Sakhar Karkhana Ltd, Kolhapur vs. ACIT, Circle-1, Kolhapur

In the result, the appeal of the assessee in ITA

ITA 2197/PUN/2024[2013-14]Status: DisposedITAT Pune15 Dec 2025AY 2013-14

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2194 To 2198/Pun/2024 िनधा"रण वष" / Assessment Years : 2010-11 To 2014-15 Shree Bhogawati Sahakari Vs. Acit, Circle-1, Sakhar Karkhana Ltd., Kolhapur. Shahunagar Parite, Sugar Factory, Shahunagar Parite, Tal- Karveer, Kolhapur- 416211. Pan : Aaaas3731R Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amit Bobde Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2010-11 To 2014-15 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2194/Pun/2024 For A.Y. 2010-11 For Adjudication As The Lead Case.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde
Section 143(1)Section 143(3)Section 250Section 36Section 36(1)

Shree Bhogawati Sahakari Sakhar Karkhana Ltd, Kolhapur vs. ACIT, Circle-1, Kolhapur

In the result, the appeal of the assessee in ITA

ITA 2196/PUN/2024[2012-13]Status: DisposedITAT Pune15 Dec 2025AY 2012-13

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2194 To 2198/Pun/2024 िनधा"रण वष" / Assessment Years : 2010-11 To 2014-15 Shree Bhogawati Sahakari Vs. Acit, Circle-1, Sakhar Karkhana Ltd., Kolhapur. Shahunagar Parite, Sugar Factory, Shahunagar Parite, Tal- Karveer, Kolhapur- 416211. Pan : Aaaas3731R Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amit Bobde Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2010-11 To 2014-15 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2194/Pun/2024 For A.Y. 2010-11 For Adjudication As The Lead Case.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde
Section 143(1)Section 143(3)Section 250Section 36Section 36(1)

Shree Bhogawati Sahakari Sakhar Karkhana Ltd, Kolhapur vs. ACIT, Circle-1, Kolhapur

In the result, the appeal of the assessee in ITA

ITA 2195/PUN/2024[2011-12]Status: DisposedITAT Pune15 Dec 2025AY 2011-12

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2194 To 2198/Pun/2024 िनधा"रण वष" / Assessment Years : 2010-11 To 2014-15 Shree Bhogawati Sahakari Vs. Acit, Circle-1, Sakhar Karkhana Ltd., Kolhapur. Shahunagar Parite, Sugar Factory, Shahunagar Parite, Tal- Karveer, Kolhapur- 416211. Pan : Aaaas3731R Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amit Bobde Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2010-11 To 2014-15 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2194/Pun/2024 For A.Y. 2010-11 For Adjudication As The Lead Case.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde
Section 143(1)Section 143(3)Section 250Section 36Section 36(1)

Shree Bhogawati Sahakari Sakhar Karkhana Ltd, Kolhapur vs. ACIT, Circle-1, Kolhapur

In the result, the appeal of the assessee in ITA

ITA 2194/PUN/2024[2010-11]Status: DisposedITAT Pune15 Dec 2025AY 2010-11

Bench: Shri Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita Nos.2194 To 2198/Pun/2024 िनधा"रण वष" / Assessment Years : 2010-11 To 2014-15 Shree Bhogawati Sahakari Vs. Acit, Circle-1, Sakhar Karkhana Ltd., Kolhapur. Shahunagar Parite, Sugar Factory, Shahunagar Parite, Tal- Karveer, Kolhapur- 416211. Pan : Aaaas3731R Appellant Respondent Assessee By : Shri Nikhil S. Pathak Revenue By : Shri Amit Bobde Date Of Hearing : 09.12.2025 Date Of Pronouncement : 15.12.2025 आदेश / Order Per Bench : These Appeals Filed By The Assessee Are Directed Against The Separate Orders Dated 26.06.2024 Passed By Ld. Cit(A)/Nfac For The Assessment Years 2010-11 To 2014-15 Respectively. 2. There Is Delay In Filing Of The Present Appeals. We Are Satisfied With The Reasons Mentioned In The Application For Condonation Of Delay Duly Supported By An Affidavit That The Appeals Within The Prescribed Time Limit. After Hearing Ld. Dr, We Condone The Delay & Proceed To Adjudicate The Appeals. 3. Since Identical Facts & Common Issues Are Involved In All The Above Captioned Five Appeals Of The Assessee, Therefore, We Proceed To Dispose Of The Same By This Common Order. 4. First, We Shall Take Up The Appeal Of The Assessee In Ita No.2194/Pun/2024 For A.Y. 2010-11 For Adjudication As The Lead Case.

For Appellant: Shri Nikhil S. PathakFor Respondent: Shri Amit Bobde
Section 143(1)Section 143(3)Section 250Section 36Section 36(1)