Section 143 Assessments: 12 Recent ITAT and HC Rulings (2026)
A structured index of 12 recent ITAT and High Court rulings on Section 143 income-tax assessments, covering scrutiny, reassessment, penalty, and related issues (2026).
This compilation indexes 12 recent rulings — from the Income Tax Appellate Tribunal (ITAT) benches across India and from the Madras and Bombay High Courts — in which Section 143 of the Income Tax Act, 1961 was among the sections engaged. The cases span the period June–July 2026 and cover a range of issues including scrutiny assessments, reassessments, penalty proceedings, employee-contribution disallowances, agricultural income, and procedural questions arising under the faceless assessment regime. The compilation is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who need a rapid-reference index of recent tribunal and court activity on Section 143 and its adjoining provisions.
Research index only. This page is a structured case-law reference tool. Nothing on this page constitutes legal advice, tax advice, or any recommendation to act or refrain from acting. Always verify against the full text of the judgment and consult a qualified adviser before relying on any ruling.
The statutory framework in one paragraph
Section 143 of the Income Tax Act, 1961 governs the processing and assessment of returns of income filed by taxpayers. Section 143(1) provides for summary processing of a return — including arithmetic corrections, disallowance of certain claims made without supporting schedules, and the issuance of an intimation — without calling the taxpayer for scrutiny. Section 143(2) empowers an Assessing Officer to issue a notice requiring the taxpayer to produce accounts or evidence if, after considering the return, the AO is of the view that it is necessary or expedient to ensure that income has not been understated or that excessive loss, deductions, allowances, or reliefs have not been claimed. Section 143(3) provides for the substantive scrutiny assessment order passed after such notice and hearing. These provisions form the primary machinery for regular assessments and interact extensively with other provisions such as Section 147 (reassessment), Section 144 (best-judgment assessment), Section 144C (dispute resolution panel for eligible assessees), and various penalty and appellate provisions.
The 12 rulings
1. Ennore Tank Terminals Private Limited vs The Additional /Joint /Deputy /
- Bench: Madras High Court
- Date: 20 July 2026
- Sections engaged: 115J, 143(1), 143(3), 147, 249, 270, 270A, 276C, 80
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The petitioner filed a writ petition under Article 226 of the Constitution before the Madras High Court (WP No. 10711 of 2022) seeking a writ of certiorari to quash an order in ITBA/PNL/F/270A/2021-22/1040918356(1) dated 16.03.2022, which imposed a penalty under Section 270A for Assessment Year 2018-19 on the ground of under-reporting of income as a consequence of misreporting. The petitioner's counsel submitted that the petitioner had claimed a deduction, the precise nature of which is not fully set out in the source preview; the High Court's final determination on the writ is not specified in the source.
2. Jones Lang Lasalle Property vs Deputy Commissioner Of Income
- Bench: Income Tax Appellate Tribunal - Delhi
- Date: 17 July 2026
- Sections engaged: 143(2), 143(3), 144C(13), 154, 36(1), 36(1)(va), 43B
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal (IT(TP)A No. 218/Del/2026) was preferred by the assessee for Assessment Year 2022-23 against the Final Assessment Order dated 25.02.2026 passed by the Assessment Unit, Income Tax Department. A notable procedural issue apparent from the source preview relates to the time limit under Section 144C(13): the DRP directions were issued on 27.12.2025, the statutory one-month time limit to pass the final order fell on 31.01.2026, and the final assessment order was dated 25.02.2026 — raising a question as to whether the final order was passed within the prescribed time limit. The substantive determination by the Tribunal is not specified in the source.
3. Dakshaben Jayendra Modi,Ghandhinagar vs Ward 1 , Gandhinagar, Gandhinar
- Bench: Income Tax Appellate Tribunal - Ahmedabad
- Date: 17 July 2026
- Sections engaged: 143(1), 154, 250
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal (ITA No. 685/AHD/2026) relates to Assessment Year 2010-11 and was filed before the ITAT Ahmedabad. The source preview indicates that a ground of appeal was taken regarding the adjustment of a refund of Rs. 19,309/- for Assessment Year 2010-11, which the assessee contended should not have been adjusted against demands for other assessment years; the assessee further referred to a CBDT order F.No. 375/02/2023-IT-Budget dated 13/02/2024 concerning the monetary limit of Rs. 25,000/- as extinguishing the revenue's claim. The Tribunal's final determination is not specified in the source.
4. Handytankers K-S vs Deputy Commissioner Of Income Tax
- Bench: Bombay High Court
- Date: 15 July 2026
- Sections engaged: 139, 143, 172(4)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The writ petition (WP No. 72 of 2024) before the Bombay High Court challenged Assessment Orders dated 30th March 2023 and the consequent demand raised for Assessment Year 2023-24. The assessment orders were passed under Section 172(4) in relation to four vessels — "Maersk Kate", "Maersk Kara", "Maersk Kiera", and "Maersk Adriatic" — and the petitioner-assessee had exercised the option under Section 172(7) before any assessment order was passed under Section 172(4) to have total income assessed and tax determined under the other provisions of the Act. The High Court's final ruling on the matter is not specified in the source.
5. M/S. Fastflow Vintrade Pvt vs DCIT, Circle 12(1), Now Circle 11(1)
- Bench: Income Tax Appellate Tribunal - Kolkata
- Date: 13 July 2026
- Sections engaged: 143
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal (ITA No. 244/Kol/2025) was filed by the assessee against the order of the NFAC, Delhi (CIT(A), Kolkata-4/11007/2019-20 dated 05.12.2024) for Assessment Year 2012-13. The assessee's authorised representative filed an additional ground described as purely legal in nature, which was admitted and taken up for adjudication; the assessee's returned income was stated to be Rs. 3,14,230/-. The Tribunal's substantive determination is not specified in the source.
6. Devranjan Mittra,South Delhi vs Assessment Unit, South Delhi
- Bench: Income Tax Appellate Tribunal - Delhi
- Date: 10 July 2026
- Sections engaged: 143, 171(3)
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal (ITA No. 5852/Del/2025) was filed against the order dated 22.07.2025 of the National Faceless Appeal Centre (NFAC), Delhi, arising out of an assessment order dated 12.03.2025 passed by the Assessment Unit for Assessment Year 2023-24. The source preview notes that the assessee Devranjan Mittra was deceased at the time of the proceedings, which appears to be a material fact relevant to the continuation of the appeal. The Tribunal's final determination is not specified in the source.
7. Manmohan Das Kurre, Raipur,Raipur vs ITO, Ward-1(2), Raipur, Raipur
- Bench: Income Tax Appellate Tribunal - Raipur
- Date: 9 July 2026
- Sections engaged: 124(3), 127, 139(1), 143(2), 143(3), 147, 148
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal (ITA No. 388/RPR/2026) relates to Assessment Year 2011-12 and was filed before the ITAT Raipur SMC Bench. The sections engaged indicate that the appeal raised questions touching on jurisdiction (including provisions relating to transfer of cases and objection to jurisdiction) alongside the substantive assessment and reassessment machinery. The Tribunal's final determination on the merits is not specified in the source.
8. Ravindrabhai Shah,Vadodara vs Deputy Commissioner Of Income Tax
- Bench: Income Tax Appellate Tribunal - Ahmedabad
- Date: 9 July 2026
- Sections engaged: 139, 142, 143(3), 147
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal (ITA No. 1187/AHD/2026) was filed against the order of the Commissioner of Income Tax, Addl/JCIT (Appeal) — Lucknow, dated 09.03.2026, for Assessment Year 2011-12 in proceedings under Section 143(3) read with Section 147. The matter thus concerns a reassessment completed as a scrutiny assessment, with the appeal originally decided at the first appellate level before coming before the ITAT Ahmedabad. The Tribunal's substantive determination is not specified in the source.
9. Mithabhi Lamps Private Limited,Delhi vs DCIT, Delhi
- Bench: Income Tax Appellate Tribunal - Delhi
- Date: 8 July 2026
- Sections engaged: 143
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal (ITA No. 8191/Del/2025) for Assessment Year 2018-19 was directed against the order of the CIT(A)/JCIT(A), Ranchi dated 22.10.2025, wherein the appeal was partly allowed. The CIT(A) had confirmed an addition of Rs. 2,50,440/- on account of employees' contribution towards PF on the ground of late deposit, following the Supreme Court's ruling in Checkmate Services P. Ltd. vs. CIT-I (2022) 448 ITR 518 (SC), while deleting additions on account of leave encashment, gratuity, and labour welfare fund. The Tribunal's final determination is not specified in the source.
10. Kalluri Ramakrishna vs The Income Tax Officer , Circle 7(1)(1)
- Bench: Income Tax Appellate Tribunal - Bangalore
- Date: 8 July 2026
- Sections engaged: 143, 144, 250
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal (ITA No. 146/Bang/2026) for Assessment Year 2020-21 was filed against the order dated 12.11.2025 passed under Section 250 by the CIT(A), National Faceless Appeal Centre, Delhi. The solitary grievance of the assessee as set out in the source preview concerned the addition made on account of the disallowance of agricultural income and agricultural expenses claimed by the assessee. The Tribunal's substantive determination is not specified in the source.
11. Sharanjeet Kaur, Raipur,Raipur vs Income Tax Officer, Ward 3(1), Raipur
- Bench: Income Tax Appellate Tribunal - Raipur
- Date: 7 July 2026
- Sections engaged: 142(1), 143(2), 143(3), 144, 147, 148(1), 153A, 292B
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal (ITA No. 553/RPR/2026) for Assessment Year 2013-14 emanated from the order of the CIT(Appeals)/NFAC, Delhi dated 09.12.2025. A significant preliminary issue was that the appeal was time-barred by 117 days; the assessee's counsel filed a condonation petition accompanied by an affidavit dated 25.06.2026, and the Senior DR did not raise any objection regarding condonation of delay. The Tribunal's ruling on condonation and the substantive merits is not specified in the source.
12. Sharmistha Mahendrakumar vs Income Tax Officer, Ahmedabad
- Bench: Income Tax Appellate Tribunal - Ahmedabad
- Date: 6 July 2026
- Sections engaged: 10, 143(1), 249, 250
- Outcome: Outcome not specified in source
- Procedural / substantive ground: The appeal (I.T.A. No. 1310/Ahd/2026) for Assessment Year 2021-22 was filed against the order of the CIT(A)-1, Jaipur dated 09.04.2026 passed under Section 250. The source preview indicates the assessee was a salaried employee working with BSNL. The appeal appears to involve a challenge to a CIT(A) order concerning a matter arising from an intimation or processing, given the sections engaged. The Tribunal's substantive determination is not specified in the source.
Patterns across these 12 rulings
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Faceless assessment and appeal infrastructure features prominently. Multiple cases — including the Fastflow Vintrade (case 5), Devranjan Mittra (case 6), Mithabhi Lamps (case 9), Kalluri Ramakrishna (case 10), and Sharanjeet Kaur (case 11) matters — arose directly from orders of the National Faceless Appeal Centre (NFAC), Delhi, reflecting the widespread reach of the faceless regime into current ITAT litigation.
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Reassessment under Section 147 frequently accompanies Section 143(3) proceedings. Cases 7 (Manmohan Das Kurre), 8 (Ravindrabhai Shah), and 11 (Sharanjeet Kaur) all engage both Section 143(3) and Section 147, indicating that reassessment-cum-scrutiny proceedings continue to generate a significant volume of appellate work across ITAT benches.
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Procedural and jurisdictional grounds appear alongside substantive challenges. Case 2 (Jones Lang Lasalle) raises a question about the time limit under Section 144C(13) for passing the final assessment order following DRP directions; case 7 (Manmohan Das Kurre) engages provisions relating to jurisdiction over assessees; and case 11 (Sharanjeet Kaur) required the Tribunal to address a 117-day delay in filing before reaching the merits. This pattern suggests that procedural compliance by the department and by taxpayers is independently live before tribunals.
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Writ jurisdiction invoked at High Court level for penalty and shipping-company assessment issues. Cases 1 (Ennore Tank Terminals, Madras HC) and 4 (Handytankers K-S, Bombay HC) represent writ petitions directly challenging assessment or penalty orders, with the Bombay matter specifically concerning the special assessment regime for shipping income under Section 172(4) and the taxpayer's exercise of an option under Section 172(7).
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Delay condonation and deceased-assessee situations create preliminary procedural hurdles. Case 11 (Sharanjeet Kaur) involves a 117-day delay requiring condonation before the appeal could be heard on the merits, and case 6 (Devranjan Mittra) involves the continuation of proceedings where the assessee had since deceased — both illustrating recurring threshold procedural issues that ITAT benches must resolve before substantive adjudication.
How to use this compilation
This compilation is a structured reference index, not a digest of final holdings. Because all 12 source previews reflect the early portions or procedural portions of the judgments, the final dispositive rulings are not available in the source data for any of these cases. Researchers should use this index to identify potentially relevant matters and then retrieve and read the full text of each judgment from indiankanoon.org, the respective High Court portals (mhc.tn.gov.in, bombayhighcourt.nic.in), or the official ITAT portal before drawing any conclusion about the law as stated in those cases.
When verifying rulings, researchers should also check whether any order has been stayed, reversed, or appealed further. ITAT orders are subject to challenge before the respective High Court under Section 260A of the Income Tax Act, and High Court orders are subject to further appeal. A ruling listed here as of July 2026 may have been subsequently stayed or overturned; the TaxNoticeAI database reflects the state of the corpus at the time of indexing and is not updated in real time.
Finally, where a ruling engages CBDT circulars or instructions (as indicated in case 3 by the reference to a CBDT order on monetary limits), researchers should verify the current status of the relevant circular or instruction, as CBDT guidance is subject to modification or withdrawal. Section 143 assessments also interact with CBDT's guidelines on faceless assessment and the e-proceedings framework, which are updated periodically and should be consulted alongside the case law.
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.
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.
Disclaimer: The information provided is for educational and informational purposes only and should not be construed as legal or tax advice. AI-generated content is a draft for professional review — always verify with applicable laws, circulars, and case law before filing. Consult a qualified Chartered Accountant or tax professional before acting on any information presented here.
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