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Section 143(1) Intimations: 12 ITAT Rulings Across India (July 2026)

12 ITAT rulings from July 2026 on Section 143(1) intimations — covering CPC processing disputes, deduction denials, condonation of delay, and reassessment chains.

Rangoli Bansal13 min read

This compilation indexes twelve Income Tax Appellate Tribunal (ITAT) orders pronounced in July 2026, each engaging Section 143(1) of the Income-tax Act, 1961, either as the primary proceeding under scrutiny or as a procedural staging point leading to further assessment or appellate action. The rulings span benches at Ahmedabad, Mumbai, Delhi, Chennai, Hyderabad, and Bangalore, and involve a range of substantive issues — from CPC-level disallowances of deductions and exemptions, to foreign tax credit denials, transfer pricing adjustments, reassessment chains, and revisionary proceedings. The compilation is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who need a structured, citation-ready index of recent ITAT activity on Section 143(1) matters.

Research index only. This page is a structured case-law index drawn from tribunal orders. Nothing on this page constitutes legal advice, tax advice, or a recommendation of any course of action. Readers should consult the full text of each judgment and qualified counsel before acting on any information contained herein.


The statutory framework in one paragraph

Section 143(1) of the Income-tax Act, 1961 provides for summary processing of a return of income by the Assessing Officer (or, in practice, the Centralised Processing Centre). Under this provision, the total income or loss is computed after making certain specified adjustments — such as arithmetical errors, incorrect claims apparent from the return, and disallowance of losses where the return of the prior year has not been furnished — and an intimation is issued to the assessee reflecting the sum determined to be payable or refundable. The intimation issued under Section 143(1) is deemed to be a notice of demand under Section 156. Importantly, Section 143(1) processing is distinct from scrutiny assessment under Section 143(3): the CPC's authority at the intimation stage is confined to the adjustments enumerated in the statute, and the intimation does not give rise to a full-fledged assessment unless the case is selected for scrutiny. The provision also prescribes a time limit within which such intimation must be sent to the assessee.


The 12 rulings

1. Arun Gokaldas Bhankhar,Ahmedabad vs Income Tax Officer,Ward7(2)(1)

  • Bench: Income Tax Appellate Tribunal - Ahmedabad
  • Date: 9 July 2026
  • Sections engaged: 10(108), 143(1), 250
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The appeal was filed against proceedings involving Section 143(1) of the Act for Assessment Years 2020-21 and 2021-22 (ITA Nos. 676-677/Ahd/2026). Per the source preview, the assessee challenged the CIT(A)'s handling of condonation of delay, contending that the lower appellate authority failed to apply the well-settled principles laid down by the Supreme Court — that substantial justice should prevail over technical considerations and that a liberal approach must be adopted when considering condonation of delay.

2. Satyapur Steel,Mumbai vs Ward 19(3)(1), Mumbai

  • Bench: Income Tax Appellate Tribunal - Mumbai
  • Date: 8 July 2026
  • Sections engaged: 132, 142(1), 143(1), 143(2), 144, 144B, 147, 148, 250, 271(1)(c), 68
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: This appeal (ITA No. 169/Mum/2026) was filed by the assessee for Assessment Year 2016-17 and was directed against the CIT(A) order dated 04.11.2025 passed under Section 250, which itself arose from an assessment order dated 08.05.2023 passed under Section 147 read with Sections 144 and 144B. Per the source preview, a preliminary issue of condonation of delay arose at the outset, as the present appeal was delayed by 4 days and the assessee filed a petition seeking condonation supported by an affidavit.

3. ACIT-Cc-4(2), Mumbai, Mumbai vs Neev Homes Private Limited, Mumbai

  • Bench: Income Tax Appellate Tribunal - Mumbai
  • Date: 8 July 2026
  • Sections engaged: 129, 142(1), 143(1), 143(2), 143(3), 250, 271(1)(c), 288A
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: This Revenue appeal (ITA No. 7861/Mum/2025) for Assessment Year 2013-14 was directed against the CIT(A)-52, Mumbai's order dated 02.09.2025 under Section 250, which arose from the assessment order dated 23.03.2016 passed under Section 143(3). Per the source preview, the respondent-assessee is a company engaged in the business of builders and developers, which had filed its return of income for A.Y. 2013-14 on 31.12.2013; the appeal was filed by the Revenue against the first appellate order.

4. Rakesh Kumar Sharma,Panipat, Haryana vs Income Tax Officer, Ward-1, Panipat

  • Bench: Income Tax Appellate Tribunal - Delhi
  • Date: 8 July 2026
  • Sections engaged: 139(1), 143(1), 143(3), 29(1)(e), 36(1), 43B
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The assessee's appeal (ITA No. 942/DEL/2026) for Assessment Year 2020-21 arose from the assessment order dated 30.11.2021 under Section 143(1) of the Act, as challenged before the Addl./JCIT(A)-2 Jaipur. Per the source preview, the assessee had filed the return of income electronically for A.Y. 2020-21 declaring total income of Rs. 86,06,260/-, but the CPC processed the ITR and assessed total income at Rs. 1,98,75,980/- without issuing any notice under Section 143(1)(a) of the Act.

5. Transsys Solutions Private vs The Income Tax Officer, Corporate Ward -

  • Bench: Income Tax Appellate Tribunal - Chennai
  • Date: 8 July 2026
  • Sections engaged: 143(1), 36(1)(va), 43B, 43B(b)
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The assessee's appeal (ITA No. 1393/CHNY/2026) for Assessment Year 2020-21 was filed against the CIT(A), NFAC, Delhi's order dated 28.10.2022, which in turn arose against the intimation issued by the Central Processing Centre, Bengaluru under Section 143(1) dated 18.12.2021. Per the source preview, the substantive issue concerned disallowances made at the CPC intimation stage, with the sections engaged pointing to disputes over employee contribution deductions and related timing provisions.

6. Ashoka Developers & Builders vs ACIT, Central Circle -1(1), Hyderabad

  • Bench: Income Tax Appellate Tribunal - Hyderabad
  • Date: 8 July 2026
  • Sections engaged: 143(1), 154, 199
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The assessee (a company engaged in construction of houses, flats, commercial complexes, and civil works) filed this appeal (ITA No. 416/Hyd/2026) for Assessment Year 2023-24, feeling aggrieved by the CIT(A)-11, Hyderabad's order dated 03.01.2026. Per the source preview, the assessee filed its return of income for A.Y. 2023-24 on 13.10.2023; the sections engaged indicate the appeal involved the interplay of the Section 143(1) intimation with a rectification proceeding under Section 154 and credit for tax deducted at source under Section 199.

7. Coca-Cola India Inc. India Branch vs DCIT, International Taxation, Circle

  • Bench: Income Tax Appellate Tribunal - Delhi
  • Date: 8 July 2026
  • Sections engaged: 143(1), 154, 92
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: This matter involved ITA No. 8275/DEL/2018 along with CO No. 73/Del/2020, with the source preview indicating the assessment year recorded as 2002-02. Per the source preview, the case involved international taxation and transfer pricing matters, with a tabulation of services provided and reimbursement of expenses valued using the Transactional Net Margin Method (TNMM), with aggregate values reflected in the order; the sections engaged indicate the dispute touched Section 143(1) in conjunction with Section 154 and Section 92 relating to computation of income from international transactions.

8. Vivek Narula,Faridabad vs Income Tax Officer, Faridabad

  • Bench: Income Tax Appellate Tribunal - Delhi
  • Date: 7 July 2026
  • Sections engaged: 139(1), 143(1), 90
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The assessee's appeal (ITA No. 4760/Del/2026) for Assessment Year 2019-20 arose from proceedings under Section 143(1) and was filed against the CIT(A)/Addl./JCIT(A)-2, Guwahati's order dated 13.03.2026. Per the source preview, both lower authorities denied the assessee's foreign tax credit claim of Rs. 2,93,330/- under Section 90 of the Act on the ground that Form 67 had not been filed or uploaded on or before the prescribed due date of filing of the return of income.

9. Swarup Co-Operative Housing Society vs Asst. Director Of Income Tax, Cpc

  • Bench: Income Tax Appellate Tribunal - Mumbai
  • Date: 7 July 2026
  • Sections engaged: 143(1), 143(1)(a), 154, 80P, 80P(2)(d), 80P(4)
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: Both appeals (ITA Nos. 4255 & 4256/Mum/2026) for Assessment Years 2020-21 and 2021-22 involved a single issue: the denial by the CPC, while processing the returns under Section 143(1), of the deduction claimed under Section 80P(2)(d) in respect of interest income earned from deposits maintained with co-operative banks — amounting to Rs. 1,96,592 for A.Y. 2020-21 and Rs. 2,10,560 for A.Y. 2021-22. Per the source preview, the assessee's subsequent rectification applications under Section 154 were also not accepted, leading to the present appeals before the Tribunal.

10. Sharadabai Charitable Trust,Mumbai vs ITO, Income Tax Appellate Tribunal

  • Bench: Income Tax Appellate Tribunal - Mumbai
  • Date: 7 July 2026
  • Sections engaged: 11, 143(1), 249(2)(b), 250
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The assessee, a registered charitable trust engaged in charitable activities, filed ITA No. 1101/MUM/2026 for Assessment Year 2018-19. Per the source preview, the trust filed its return of income declaring Nil income and claiming exemption under Section 11 of the Act; however, when the return was processed under Section 143(1), the exemption was rejected and total income was determined at Rs. 29,34,587/- solely on the ground that Form No. 10B had not been filed, with the appeal proceeding to examine the validity of this disallowance at the intimation stage.

11. Sai Dutta Clearing Agency Pvt vs ITO Ward 2(3)(1), Mumbai, Mumbai

  • Bench: Income Tax Appellate Tribunal - Mumbai
  • Date: 7 July 2026
  • Sections engaged: 115B, 142(1), 143(1), 143(3), 147, 148, 69A
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The assessee, a private limited company engaged in Customs House Agent (CHA) services and holding a valid CHA licence issued by the Customs Department, filed its original return of income on 22.09.2014 for Assessment Year 2014-15 declaring a business loss of Rs. 97,64,470/-. Per the source preview, the return was initially processed under Section 143(1) and the case was thereafter subjected to scrutiny, culminating in an assessment under Section 143(3); the appeal before the Tribunal (pronounced 7 July 2026) arose from the chain of proceedings that followed.

12. Creditaccess Grameen vs Principal Commissioner Of Income Tax -

  • Bench: Income Tax Appellate Tribunal - Bangalore
  • Date: 7 July 2026
  • Sections engaged: 139(1), 143(1), 143(3), 144B, 170A, 263, 35D, 36(1)(viia), 80J
  • Outcome: Outcome not specified in source
  • Procedural / substantive ground: The assessee filed ITA No. 341/Bang/2026 for Assessment Year 2022-23 against the revisionary order dated 17.11.2025 passed under Section 263 by the Principal Commissioner of Income Tax, Bengaluru-2, which held that the assessment order dated 18.03.2024 passed under Section 143(3) read with Section 144B was erroneous and prejudicial to the interests of the Revenue. Per the source preview, the assessee had e-filed its original return of income for A.Y. 2022-23 under Section 139(1), and the revisionary proceedings formed the substantive focus of this appeal, with Section 143(1) appearing as part of the broader assessment chain.

Patterns across these 12 rulings

  1. Section 143(1) as a gateway proceeding. Across multiple cases in this set — including Sai Dutta Clearing Agency (case 11), Creditaccess Grameen (case 12), and ACIT vs. Neev Homes (case 3) — the Section 143(1) intimation appears not as the terminal proceeding but as the first step in a chain that leads to scrutiny under Section 143(3), reassessment under Section 147, or revision under Section 263. Researchers should note the cascading procedural structure when tracing the full dispute history.

  2. CPC-level disallowances of deductions and exemptions. Cases such as Swarup Co-operative Housing Society (case 9), Sharadabai Charitable Trust (case 10), and Transsys Solutions Private (case 5) all share the feature that the substantive dispute originated in a disallowance made by the CPC while processing returns under Section 143(1) — involving the denial of Section 80P(2)(d) interest deductions, rejection of Section 11 exemptions for want of Form 10B, and disallowances of employee contribution deductions respectively.

  3. Condonation of delay as a threshold issue. Both Arun Gokaldas Bhankhar (case 1) and Satyapur Steel (case 2) present condonation of delay as a significant preliminary issue arising before the merits of the Section 143(1) dispute could be addressed. This reflects a recurring procedural pattern in ITAT appeals where delay in filing before the CIT(A) or the Tribunal itself must be resolved before substantive examination proceeds.

  4. Foreign tax credit and procedural compliance disputes at intimation stage. Vivek Narula (case 8) illustrates a category of Section 143(1) disputes where the CPC or the lower appellate authorities have denied a credit — in that case, a foreign tax credit claim under Section 90 — on procedural grounds relating to the timing or mode of filing supporting forms, with the merits of the credit itself not being independently disputed.

  5. Multi-section complexity in reassessment and transfer pricing matters. Cases such as Satyapur Steel (case 2, involving Sections 147, 144, 144B, 68, and 271(1)(c)) and Coca-Cola India Inc. (case 7, involving Section 92 and international taxation) demonstrate that Section 143(1) can appear in disputes that are substantively about reassessment or transfer pricing, with the intimation provision serving as a reference point for the original processing history rather than the central legal issue on appeal.


How to use this compilation

This index is a starting point for legal research, not a substitute for reading the full text of each judgment. Every case summarised above should be retrieved from its primary source — IndianKanoon, the ITAT official portal, or the relevant High Court portal — and read in full before it is cited in any legal submission, opinion, or compliance document. The outcome direction field for all twelve cases in this compilation is recorded as "Outcome not specified in source," meaning the dispositive conclusions of the Tribunal are not definitively captured in the previewed text; researchers must access the complete order to determine the final ruling, any directions given, and any conditions attached.

Before relying on any ruling indexed here, researchers should also verify whether the order has been challenged in a further appeal before the High Court or the Supreme Court, whether any stay has been granted against its operation, and whether any CBDT instruction, circular, or notification has been issued that may affect the position taken in the judgment. Tax law is subject to frequent legislative amendment and judicial reconsideration; a ruling pronounced in July 2026 may already be under challenge or may have been distinguished in a subsequent order by the time this compilation is accessed.

Finally, users should note that the sections cited in each case reflect the sections engaged in the proceeding as a whole — they do not necessarily indicate that every section listed was the subject of a substantive finding. The "Sections engaged" line should be read as a research filter (to identify cases that touch a given section) rather than as a holding that the Tribunal ruled on every listed section.


Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

RB

Rangoli Bansal

Editorial Reviewer & CA Finalist

CA Finalist (ICAI), B.Com (Hons.) Delhi University. 7+ years across audit, internal controls, SOX 404, ICFR, RCSA, and GRC. Hands-on experience with GST and income-tax compliance filings, statutory audit, and internal audit. Editorial reviewer for TaxNoticeAI's case-law content.

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