This compilation indexes twelve recent orders from the Income Tax Appellate Tribunal (ITAT) benches across India and one High Court, all engaging Section 143(3) of the Income Tax Act, 1961. The cases span assessment years from 2010-11 through 2024-25 and involve a diverse range of taxpayers — from pharmaceutical companies and construction firms to individual assessees — making this collection a useful reference point for researchers tracking the procedural and substantive contours of scrutiny assessments in current ITAT practice.

Research index only. This page is a structured case-law reference tool. Nothing on this page constitutes legal advice, tax advice, or a recommendation of any course of action. Readers should verify all information against the full text of each judgment and consult qualified professionals as appropriate.

The statutory framework in one paragraph

Section 143(3) of the Income Tax Act, 1961 governs the making of a scrutiny assessment by an Assessing Officer after the issuance of a notice under Section 143(2). Upon receipt of evidence furnished by the assessee, the Assessing Officer is empowered to assess or reassess the total income (or determine the loss sustained) and compute the tax payable, passing an assessment order accordingly. The provision is the primary mechanism through which the revenue undertakes a detailed examination of a return of income selected for scrutiny, and the resulting order forms the foundation for further appellate proceedings before the Commissioner of Income Tax (Appeals) and the ITAT.

The 12 rulings

1. Torque Pharmaceuticals Private Ltd vs DCIT, Central Circle-2, Chandigarh

Bench: Income Tax Appellate Tribunal - Chandigarh
Date: 21 April 2026
Sections engaged: 1, 11, 110, 11U, 132, 143(3), 147, 148, 148B, 17, 2, 20, 36(1), 36(1)(iii), 37, 533, 56(2), 56(2)(x), 69C, 7
Procedural / substantive ground: This matter before the Chandigarh bench involved M/s Torque Pharmaceuticals Pvt. Ltd. for assessment year 2021-22, arising from an assessment order. The case engages a broad range of provisions including those relating to search, reassessment, and income characterisation. The text preview indicates the appeal was heard on 17 March 2026 and the order was pronounced on 21 April 2026.

2. DCIT, Central Circle 01 New Delhi vs Sanjay Jain, New Delhi

Bench: Income Tax Appellate Tribunal - Delhi
Date: 17 April 2026
Sections engaged: 1, 127, 132, 143(3), 153A, 153C, 153D, 85
Procedural / substantive ground: This matter involved cross-objections filed by the assessee alongside departmental appeals covering assessment years 2010-11, 2011-12, and 2012-13. The sections engaged indicate the dispute arises in the context of a search-related assessment, with provisions governing assessments in search cases forming a central part of the controversy alongside Section 143(3).

3. M/S. Perq Advertising Pvt Ltd, Mumbai vs DCIT, Circle 2(3)(1), Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 17 April 2026
Sections engaged: 133(6), 143(3), 147, 2, 21, 271(1), 271(1)(c), 3, 43
Procedural / substantive ground: These were two appeals by the same assessee for assessment years 2010-11 and 2011-12, challenging an order of the National Faceless Appeal Centre (NFAC), Delhi, which confirmed a penalty. The text preview indicates the appeals concerned penalty proceedings, with Section 271(1)(c) among the provisions engaged alongside the underlying Section 143(3) assessment.

4. Sanjay Singh vs Income Tax Officer

Bench: Jharkhand High Court
Date: 06 April 2026
Sections engaged: 143(3), 154
Procedural / substantive ground: This writ petition (W.P.(T) No.7280 of 2023) was filed before the Jharkhand High Court at Ranchi by Sanjay Singh against the Income Tax Officer, Ward No.3(1), Ranchi, and the Principal Commissioner of Income Tax, Ranchi. The matter engages Section 143(3) alongside Section 154, which relates to rectification of mistakes apparent from the record.

5. Jesabhai Rajabhai Khtana, Khajuri (and others) vs Income-Tax Officer, Ward-1(2)(3), Rajkot

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 30 March 2026
Sections engaged: 10(37), 143(3), 250, 28, 34, 56, 56(2)(viii)
Procedural / substantive ground: This batch of appeals before the Rajkot bench covered assessment year 2016-17 and involved multiple assessee-appellants from Khajuri Gundala, Jetpur. The sections engaged include provisions relating to agricultural income exemption and income from other sources, suggesting the disputes concern the characterisation of receipts in the hands of the assessees under the scrutiny assessment framework.

6. DCIT CC 5 2, Mumbai vs Kalyan Vyapaar Private Limited, Mumbai

Bench: Income Tax Appellate Tribunal - Mumbai
Date: 27 March 2026
Sections engaged: 1, 143(3), 148, 14A, 3, 32, 5, 51, 68, 8
Procedural / substantive ground: This was a departmental appeal before the Mumbai bench covering assessment years 2011-12, 2013-14, and 2015-16. The sections engaged include provisions relating to unexplained cash credits under Section 68 and disallowance of expenditure under Section 14A, alongside the underlying scrutiny assessment and reassessment framework.

7. R N Constructions, Hyderabad vs DCIT, Central Circle-1(2), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 25 March 2026
Sections engaged: 11, 132, 139, 143(2), 143(3), 153, 153A, 250, 270, 270A, 270A(9), 274, 35, 51, 67, 7
Procedural / substantive ground: This appeal for assessment year 2017-18 arose in a search context, with Section 153A assessments featuring alongside the Section 143(3) order. The sections engaged also include penalty provisions under Section 270A, indicating that the dispute encompasses both substantive additions made in the scrutiny assessment and consequential penalty proceedings.

8. Kavya Boppana, Hyderabad vs ACIT, Central Circle-2(3), Hyderabad

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 25 March 2026
Sections engaged: 1, 115, 115B, 127, 132, 132(4), 139, 139(1), 14, 143(3), 24, 271A, 274, 3, 69, 69A, 74, 770
Procedural / substantive ground: This assessee appeal for assessment year 2020-21 arose from a penalty order, with the text preview indicating the dispute concerned a penalty under a search-related provision. The sections engaged include provisions relating to undisclosed income, statements recorded during search under Section 132(4), and provisions governing unexplained investments under Sections 69 and 69A.

9. Mukesh Kumar Chaurasia, Guwahati vs ACIT, Central Circle-2, Guwahati

Bench: Income Tax Appellate Tribunal - Gauhati
Date: 19 March 2026
Sections engaged: 132, 132(4), 139(1), 14, 143(2), 143(3), 250, 271A, 450, 5, 56, 7
Procedural / substantive ground: These two assessee appeals for assessment years 2023-24 and 2024-25 were heard by the Guwahati DB Bench sitting at Kolkata (virtual court). The appeals arose from separate orders of the Commissioner of Income Tax (Appeals)-Central NER, Guwahati under Section 250, with the underlying matters involving search-related proceedings and the scrutiny assessment framework under Section 143(3).

10. GE Engine Services LLC, United States of America vs Assistant Commissioner of Income Tax

Bench: Income Tax Appellate Tribunal - Delhi
Date: 11 March 2026
Sections engaged: 14, 143(2), 143(3), 144C, 144C(13), 144C(5), 37, 471, 9(1), 9(1)(vii), 976
Outcome: Taxpayer succeeded
Procedural / substantive ground: This appeal by GE Engine Services LLC (USA) was directed against the Final Assessment Order passed under Section 143(3) read with Section 144C(13), which governs the procedure applicable to eligible assessees including foreign companies. The case involves treaty-related arguments, with Section 9(1)(vii) engaged on the question of income deemed to accrue or arise in India.

11. Bijay Kumar Garodia, Kolkata vs DCIT, Central Circle 3(4), Kolkata

Bench: Income Tax Appellate Tribunal - Kolkata
Date: 05 March 2026
Sections engaged: 132, 132(1), 132(4), 143(3), 2, 218, 250, 271A, 44A, 5, 57
Procedural / substantive ground: This assessee appeal for assessment year 2013-14 arose from an order of the Commissioner of Income Tax (Appeals)-Kolkata-26 passed under Section 250. The case engages search-related provisions including Section 132(1) and 132(4) alongside the scrutiny assessment under Section 143(3), indicating a post-search assessment context.

12. Sarvanand Sadhuram Sonwani, Rajkot vs DCIT, CC-1, Rajkot

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 23 February 2026
Sections engaged: 1, 143(3), 147, 148, 2, 28, 3, 44, 54, 56, 69A
Procedural / substantive ground: This batch of appeals covered a wide span of assessment years from 2012-13 to 2022-23, including special bench appeals, before the Rajkot bench. The sections engaged include reassessment provisions under Sections 147 and 148 alongside the scrutiny assessment framework, with Section 69A (unexplained money) and Section 54 (capital gains exemption) also in play.

Patterns across these 12 rulings

Search-linked assessments predominate. A significant proportion of the cases in this set — including matters from Chandigarh, Delhi (Sanjay Jain), Hyderabad (R N Constructions and Kavya Boppana), Kolkata (Bijay Kumar Garodia), and Guwahati (Mukesh Kumar Chaurasia) — engage search-related provisions such as Sections 132, 132(1), 132(4), 153A, and 153C alongside Section 143(3). This reflects the frequency with which post-search assessments generate appellate disputes that ultimately cite Section 143(3) as the foundational assessment vehicle.
Reassessment provisions frequently accompany Section 143(3). Several cases — including Torque Pharmaceuticals (Chandigarh), Kalyan Vyapaar (Mumbai), and Sarvanand Sadhuram Sonwani (Rajkot) — cite Sections 147 and 148 alongside Section 143(3), indicating that the original or reassessment order under Section 143(3) is frequently the subject of challenge in the same set of proceedings.
Penalty proceedings often run in parallel. Cases such as Perq Advertising (Mumbai), R N Constructions (Hyderabad), and Kavya Boppana (Hyderabad) show penalty provisions — including Sections 271(1)(c), 270A, and 271A — engaged alongside the underlying Section 143(3) assessment. This underscores that substantive additions made in scrutiny assessments frequently give rise to connected penalty disputes heard by the same bench.
International tax disputes invoke the Section 143(3)/144C combination. The GE Engine Services LLC matter illustrates a distinct category in which Section 143(3) is invoked in conjunction with Section 144C, the dispute resolution mechanism applicable to eligible assessees such as foreign companies, covering issues such as characterisation of payments and treaty entitlements.
Geographic spread across ITAT benches. The 12 cases span ITAT benches at Chandigarh, Delhi, Mumbai, Hyderabad, Rajkot, Gauhati, and Kolkata, as well as the Jharkhand High Court. This breadth suggests that Section 143(3)-related disputes are not concentrated in any single jurisdiction and that researchers should monitor all major benches for relevant developments.

How to use this compilation

This index is intended as a starting point for legal research, not a substitute for reading the full text of each judgment. Every entry in this compilation should be verified against the complete order as published on the official court portal or indiankanoon.org before being cited in any submission, memo, or opinion. Case outcomes and reasoning may be more nuanced than a summary can convey, and material portions of a judgment may not be captured in the text preview on which some entries are based.

Researchers should also check whether any order listed here has been stayed, reversed, or otherwise disturbed by a superior court. An ITAT order may be the subject of an appeal before the relevant High Court, and a High Court order may be pending before the Supreme Court. The date of the order as listed reflects the date of pronouncement, not necessarily the date on which the order attained finality. Parallel CBDT circulars, instructions, and notifications relevant to the provisions cited in each case should similarly be consulted, as administrative guidance can affect how a statutory provision is applied in practice.

For practitioners using this database to build arguments or identify opposing precedents, it is advisable to run parallel searches by assessment year, section number, and bench to ensure that contrary rulings issued around the same period are not overlooked. Tax law in India evolves rapidly, and a ruling from one bench — even on a recurring issue — does not bind co-ordinate or superior authorities unless it has been affirmed on appeal or accepted as settled by the CBDT.

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.

Section 143(3) Scrutiny Assessments: 12 ITAT & HC Rulings (2026)