“Section 143(1)(a)”

Section References (mined)Section 143Section 143(1)(a)2,323 judgments

The decision most relied on for Section 143(1)(a) is Collector, Land Acquisition v. Mst. Katiji (167 ITR 471), cited in 3,926 judgments on BharatTax.

Leading authorities on Section 143(1)(a)

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. 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.

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.

Estate of Late Tukojirao Holkar v. CWT

223 ITR 480 · 1997 · High Court

2,040

citing judgments

A court or tribunal is not bound to answer a reference or adjudicate an appeal on its merits if the party at whose instance the proceeding is made fails to appear at the hearing or take necessary steps for its proper conduct.

Judgments citing Section 143(1)(a)

Quarter Deck, Mumbai vs. DCIT, CPC, CPC Bangalore

In the result, this appeal is allowed

ITA 1381/MUM/2021[2018-19]Status: DisposedITAT Mumbai28 Apr 2022AY 2018-19

Section 143Section 143(1)Section 143(1)(a)Section 154Section 36(1)(va)Section 44A

learned CIT(A) was not justified in upholding the adjustment, made by the Centralized Processing Centre Bengaluru while processing income tax returns under section 143(1) based on certain inputs from the tax audit reports of the assessee in question, in respect of the disallowance ... total of such, as perceived by the tax auditor, delayed payments, aggregating to Rs 4,24,634 ,were sought to be disallowed under section 143(1). When the assessee was put to notice, by the Dy Commissioner of Income Tax, CPC, Bangalore (hereinafter referred to as „the Assessing Officer

Forcepoint Software Consulting India Pvt. Ltd, Mumbai vs. ADIT, CPC, Bangalore

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

ITA 6/MUM/2022[2019-20]Status: DisposedITAT Mumbai27 Apr 2022AY 2019-20

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhailforcepoint Software Vs. Assistant Director Of Consulting India Pvt. Income Tax, Cpc Ltd., Level 2, Kalpataru Bangalore Synergy Opp. Grand Karnataka 560500 Hyatt, Santacruz (East) Mumbai- 400055 "थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaacw6672P Appellant .. Respondent

For Appellant: Renu KapoorFor Respondent: S.N. Kabra

Section 139(1)Section 143(1)Section 143(1)(a)Section 36(1)(va)Section 43B

facts of the case in confirming the assessment made by Ld. Assistant Director of income tax, CPC ('AO CPC') by passing intimation under section 143(1) of the income tax act, 1961 ('the act') in case of the appellant at Rs.8,68,84,190/- as against the returned income ... section 36(1)(va) of the act of Rs. 14,90,835/-under the head income from business in the intimation issued under section 143(1) of the act without appreciating the fact that such addition does not constitute as prima facie adjustment under section 143(1

Kalpesh Synthetics Pvt Ltd, Mumbai vs. DCIT CPC, Bangalore, Bengaluru

In the result, this appeal is allowed

ITA 1910/MUM/2021[2019-20]Status: HeardITAT Mumbai27 Apr 2022AY 2019-20

Section 143Section 143(1)Section 143(1)(a)Section 154Section 36(1)(va)Section 44A

Bishnucharan Bharat Mohanty, Mumbai vs. ITO WD 26(1) (1), Mumbai

In the result the appeals by the assessees are allowed

ITA 1906/MUM/2021[2018-19]Status: DisposedITAT Mumbai27 Apr 2022AY 2018-19

Bench: Shri Shamim Yahya (Am) Assessment Year: 2019-20 Matrix Integreted Products Llp Vs. Adit(Cpc)-Ward 27 (2)(2) 213/5746, 2Nd Floor, Aruodya Darshan, Navi Mumbai 400 703 90 Feet Road Ghatkopar (E), Mumbai 400 075 Appellant. Respondent. Pan Abcfm7193D Assessee By : None Revenue By : Ms. Usha Gaikwad Assessment Year: 2018-19 Bishnucharan Bharat Mohanty, Vs. Ito, Ward 29 (1)(2) B-4, Maichael Sadan, Laxmi Udyog Nagar, Mumbai 400051 Kanjur Marg (W) Mumbai 400078 Appellant. Respondent. Pan Aqepm6398K Assessee By : None Revenue By : Ms. Usha Gaikwad

For Appellant: NoneFor Respondent: Ms. Usha Gaikwad

Section 143(1)Section 143(1)(a)Section 36(1)(va)

confirming that adjustment made by the learned Deputy Commissioner of Income Tax, CPC („the AO‟) are within the purview of section 143(1)(a) of the Income Tax Act, 1961 (the Act) which relate to disallowance u/s. 36(1)(va) of that of the employees contribution to PF & ESI dues

Matrix Integrated Products LLP, Mumbai vs. WD 27(2) (2), Mumbai

In the result the appeals by the assessees are allowed

ITA 1905/MUM/2021[2019-20]Status: HeardITAT Mumbai27 Apr 2022AY 2019-20

For Appellant: NoneFor Respondent: Ms. Usha Gaikwad

Section 143(1)Section 143(1)(a)Section 36(1)(va)

Associated Hospitality and Developers Pvt. Ltd, Mumbai vs. Dy CIT, CPC, Mumbai

In the result the appeals by the assessees are allowed

ITA 1747/MUM/2021[2018-19]Status: HeardITAT Mumbai27 Apr 2022AY 2018-19

Bench: Shri Shamim Yahya (Am) Assessment Year: 2018-19 Starline Workshop, Vs. Ito-Ward1(1) 1 C/O Sterling Motor Compound, Nashik 422 002 Old Agra Road, Gadkari Chowk, Nashik 422001 Appellant. Respondent. Pan Acbfs2289L Assessee By : Shri Ryan Saldanha Revenue By : Ms. Usha Gaikwad Assessment Year: 2019-20 Vishnu Sadu Gade, Vs. Dcit, Circle -3 C-3, 302, Ashar Estate, Thane 400 604 Shreenagar, Thane (W)-400604 Appellant. Respondent. Pan Aabpg4702C Assessee By : None Revenue By : Ms. Usha Gaikwad Assessment Year: 2018-19 Associated Hospitality & Developers Pvt. Ltd., Vs. Dcit, Cpc 4Th Floor, Techniplex-I, Techniplex Complex, Veer Savarkar Flyover, Goregaon (W), Mumbai 400 062 Appellant. Respondent. Pan Aafca7847P Assessee By : Shri Rajesh Shah Revenue By : Ms. Usha Gaikwad Assessment Year: 2018-19 M/S. Vasundhara Packaging Industry, Vs. Cit(A)- (Faceless) 501, Blue Bell, Royal Complex, Eksar Road, Borivali (W), Mumbai 400 092 Appellant. Respondent. Pan Aadfv0326M Assessee By : Shri Ajay Singh Revenue By : Ms. Usha Gaikwad

For Appellant: Shri Ryan SaldanhaFor Respondent: Ms. Usha Gaikwad

Section 143(1)Section 143(1)(a)Section 36(1)(va)

Vishnu Sadu Gade, Mumbai vs. DCIT, Cir. 3, Thane

In the result the appeals by the assessees are allowed

ITA 1746/MUM/2021[2019-20]Status: DisposedITAT Mumbai27 Apr 2022AY 2019-20

For Appellant: Shri Ryan SaldanhaFor Respondent: Ms. Usha Gaikwad

Section 143(1)Section 143(1)(a)Section 36(1)(va)

Sangeeta Udayraj Singh, Mumbai vs. ADIT CPC, Bengaluru

In the result, the appeal by the assessee is allowed and the orders of the authority below are set aside

ITA 1713/MUM/2021[2019-20]Status: DisposedITAT Mumbai27 Apr 2022AY 2019-20

Bench: Learned Cit(A). Learned Cit(A) Confirmed The Action Of Cpc By Holding As Under : 5.41. I Have Carefully Considered The Arguments Of The Appellant As Well As Various Decisions Cited By The Appellant. In The Instant Case, Disallowance Has Been Made U/S 36(1)(Va) R.W.S. 2(24)(X) Of The Act On The Ground That The Employees' Contribution To Esic Were Deposited Much After The Specified Dates Mentioned In The Said Act & The Same Is Clearly Mentioned In The Tax Audit Report.

Section 143(1)Section 143(1)(a)Section 36(1)Section 36(1)(va)

income of Rs. 22,62,260/- being late payment of Employees Contribution to Provident Fund. 2. The above addition is not sustainable under section 143(1). 3. Brief facts of the case are that in the order under section 143(1) of the I.T. Act passed by CPC, Bangalore disallowing ... section 36(1)(va) is strictly in accordance with law and clearly comes under the prima facie adjustments as envisaged under section 143(1)(a)(iv). The order under section 143(1) issued by CPC is therefore confirmed fully. Appellant’s ground on the issue falls.” 5. Against this order

M/S. Vasundhara Packaging Industry, Mumbai vs. ITO 32 (1) (1), Mumbai

In the result the appeals by the assessees are allowed

ITA 1575/MUM/2021[2018-19]Status: DisposedITAT Mumbai27 Apr 2022AY 2018-19

For Appellant: Shri Ryan SaldanhaFor Respondent: Ms. Usha Gaikwad

Section 143(1)Section 143(1)(a)Section 36(1)(va)

Bengaluru International Group of Service, Bengaluru vs. The Assistant Director of Income Tax, CPC, Bengaluru

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

ITA 648/BANG/2021[2018-19]Status: DisposedITAT Bangalore31 Mar 2022AY 2018-19

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2018-19 M/S. Bengaluru International Group Of Service, The Assistant Site No. 4 & 12, Sy.No. 96/1, Director Of Income Near South Ridge Apartment, Tax, Jakkur, Cpc, Bangalore – 560 064. Vs. Bangalore. Pan: Aalfb2496G Appellant Respondent Assessee By : Shri Prabhakar .K.R, Ca : Shri Priyadarshi Mishra, Addl. Revenue By Cit (Dr) Date Of Hearing : 31-03-2022 Date Of Pronouncement : 31-03-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Order Dated 01.10.2021 U/S. 250 Passed By The National Faceless Appeal Centre (Nfac), Delhi Relating To Assessment Year 2018-19 On Following Grounds Of Appeal: “1. The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (Herein After Called Cit(A), Is Opposed To Law, Evidences, Probabilities & Facts & Circumstances Of The Case. 2. The Learned Cit(Appeals) Erred In Confirming The Disallowance Amounting To Rs.79,99,158/- Made By The Assistant Director Of Income Tax, Cpc, Bengaluru, (Ao For Short) In Respect Of The Claim Towards Employees'

For Appellant: Shri Prabhakar .K.R, CA

Section 139(1)Section 143Section 143(1)Section 143(1)(a)Section 250Section 36(1)(va)

date of payment of employees' contribution towards ESI and PF and does not indicate any disallowance of expenditure as contemplated in Section 143(1)(a)(iv). 6. The learned CIT(Appeals) overlooked the fact that AO did not "consider" the response given by the appellant, before making any adjustment

Shri Rajeev Nataraj Legal Heir of Late Shri P Nataraj, Bangalore vs. Income Tax Officer Ward-10(2), Bangalore

In the result appeal filed by assessee stands allowed

ITA 848/BANG/2019[2008-09]Status: DisposedITAT Bangalore31 Mar 2022AY 2008-09

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2008-09 Shri Rajeev Nataraj, L/H Of Late Shri P Nataraj, No. 63, 1St Cross, The Income Tax Udaya Nagar, Officer, Chikkalsandra, Off Ward 10(2), Uttarahalli Road, Bangalore. Vs. Bangalore – 560 061. Pan: Ahapn9475D Appellant Respondent Assessee By : Shri H. Siva Prasad Reddy, Ar : Shri Priyadarshi Mishra, Addl. Revenue By Cit (Dr) Date Of Hearing : 09-02-2022 Date Of Pronouncement : 31-03-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Order Dated 11/02/2019 Passed By The Ld.Cit(A)-3, Bangalore For Assessment Year 2008-09 On Following Grounds Of Appeal: “1. The Impugned Order Passed By The Learned Commissioner Of Income-Tax [Appeals] U/S 250 Of The Act & That Of The Order Of Assessment Passed By The Learned Assessing Officer Under Section 143[3] R/W 147 Of The Act To The Extent Which Is Against The Appellant Is Opposed To Law, Weight Of Evidence, Probabilities, Facts & Circumstances Of The Appellant'S Case. 2. The Order Of Assessment Passed By The Learned Assessing Officer Under Section 143[3] R.W.S 147 Of The Act Is Bad In Law Since The Mandatory Conditions As Envisaged

For Appellant: Shri H. Siva Prasad Reddy, AR

Section 143Section 234Section 250Section 54

passed in case of assessee for assessment year under consideration. We note that the Ld.AO at the time of issuing intimation under section 143(1)(a), observed that assessee claimed exemption under section 54 on two residential properties, and in order to verify the alleged excess claim, issued notice under

The Maharashtra State Co. Op.Banks Association, Mumbai vs. AO CPC Bengaluru, Karnataka

In the result, appeal filed by the assessee is allowed

ITA 1633/MUM/2021[2018-19]Status: DisposedITAT Mumbai30 Mar 2022AY 2018-19

Bench: Shri Shamim Yahya

Section 143(1)Section 249(3)Section 80P(2)(c)

benefit of the consumers;]" 8. First of all it is noted that the adjustment has been done by the CPC Bengaluru under section 143(1)(a) of the Act. Section 143(1)(a) provides for processing of return where the total income is computed after making certain adjustment. It reads ... exemption on the interest earned on deposits in cooperative bank is not something which is a subject matter of adjustment under section 143(1)(a) of the Act. I find that despite noting that there are tribunal decisions in favour of assessee, the learned CIT(A) has chosen

M/S. Rahul Impex, Mumbai vs. ITO-26(3) (1), Mumbai

In the result, the appeal by the assessee is allowed and the orders of the authorities below is set aside

ITA 1629/MUM/2021[2012-13]Status: DisposedITAT Mumbai30 Mar 2022AY 2012-13

Bench: Shri Shamim Yahya

Section 143(1)Section 143(1)(a)Section 2Section 36Section 43B

Income Tax (Appeals)-14 dated 29.07.2021 and pertains to assessment year 2017-18. 2. Grounds of appeal read as under:- Intimation under section 143(1) beyond jurisdiction 1. Erred in upholding action of AO by confirming that adjustment made by the learned Deputy Commissioner of Income ... within the purview of section 143(1)(a) of the Income-tax Act, 1961 (the Act). 2. Failed to appreciate that the issue is debatable in view of contrary views of different High courts and hence no adjustment under section 143(1)(a) is warranted. Ground No.2 : Disallowance

Roopa Sampath Kumar, Bangalore vs. Assistant Director of Income Tax, CPC, Bangalore

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

ITA 624/BANG/2021[2019-20]Status: DisposedITAT Bangalore28 Mar 2022AY 2019-20

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiassessment Year : 2019-20 Ms. Roopa Sampath Kumar, The Assistant No. 103, Blue Cross Director Of Income Chambers, Tax, Infantry Road, Cpc, Bangalore – 560 Vs. Bangalore. 001. Pan: Ablpk3199A Appellant Respondent Assessee By : Shri Sandeep Chalapathy, Ca : Shri Priyadarshi Mishra, Addl. Revenue By Cit (Dr) Date Of Hearing : 28-03-2022 Date Of Pronouncement : 28-03-2022 Order Per Beena Pillaipresent Appeal By The Assessee Has Been Filed By Assessee Against The Order Dated 29.10.2021 U/S. 250 Passed By The National Faceless Appeal Centre (Nfac), Delhi Relating To Assessment Year 2019-20 On Following Grounds Of Appeal: “1. That The Order Of The Learned Commissioner Of Income Tax (Appeals) — Nfac, Delhi, In So Far Is Prejudicial To The Interest Of The Appellant, Is Bad & Erroneous In Law & Against The Facts & Circumstances Of The Case. 2. That The Learned Commissioner Of Income Tax (Appeals) - Nfac, Delhi Erred In Law & On Facts In Confirming The Addition Of Employees' Contribution Towards Provident Fund & Employees' State Insurance Of Rs.5,17,229/- Without

For Appellant: Shri Sandeep Chalapathy, CA

Section 139(1)Section 143(1)Section 143(1)(a)Section 250Section 36(1)(va)Section 43B

facts in making disallowance u/s 43B of the Act even though such disallowance does not fall under the purview of section 143(1)(a) of the Act. Each of the above grounds is without prejudice to one another, the appellant craves the leave of the Hon'ble Income Tax Appellate

Insurekot Sports P Ltd, Mumbai vs. Dy CIT, CPC, Mumbai

In the result, appeal by the assessee stands allowed

ITA 1075/MUM/2021[2017-18]Status: DisposedITAT Mumbai25 Mar 2022AY 2017-18

Bench: Learned Cit(A). Learned Cit(A) Noted The Facts Of The Case & Assessee’S Submission As Under :- “Assessee Has Availed Of A Franchiseeship Of Team Puneri Paltan Which Is A Participating Team In The Pro Kabaddi League Organized By Mashal Sports Private Limited. During Fy 2016 17 Ay 2017 18 It Received Prize Money Of Rs 3000000 Being The Third Placed Team Of The Event. The Same Is Accounted & Shown Under The Revenue From Operations As Prize Money. The Same Is 2 Insurekot Sports Pvt. Ltd.

Section 115BSection 143Section 143(1)Section 2(24)(ix)Section 56(2)(ib)

dated 29.4.2021 pertaining to A.Y. 2017-18. 2. The grounds of appeal raised read as under :- 1) Adjustments beyond powers under section 143(1). 2) Invalid proceedings under section 143(1) and violation of principal of natural justice. 3) Addition of Rs. 30 lakhs under income from other sources ... gross amount. 5) Double taxation 3. Brief facts of the case are that in this case adjustment was done under section 143(1). Pursuant to the same assessee filed appeal before learned CIT(A). Learned CIT(A) noted the facts of the case and assessee’s submission as under :- “Assessee

M/S Bbr (India) Pvt Ltd, Bangalore vs. Deputy Commissioner of Income Tax, CPC, Bangalore

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

ITA 92/BANG/2022[2017-18]Status: DisposedITAT Bangalore24 Mar 2022AY 2017-18

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

For Appellant: Sri.Ramasubramaniam, CAFor Respondent: Sri.Priyadarshini Mishra, Addl.CIT-DR

Section 139(1)Section 143(1)Section 143(1)(a)Section 36Section 36(1)(va)Section 43B

facts in making disallowance u/s 43B of the Act even though such disallowance does not fall under the purview of section 143(1)(a) of the Act. Each of the above ground is without prejudice to one another, the appellant craves the leave of the Hon’ble Income Tax Appellate

M/S Google India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Centralized Processing Centre, Bangalore

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

ITA 81/BANG/2022[2017-18]Status: DisposedITAT Bangalore23 Mar 2022AY 2017-18

Bench: Shri Chandra Poojari, Am & Smt.Beena Pillai, Jm

For Appellant: Sri.Aliasgar Rampurwala, CAFor Respondent: Sri.Priyadarshini Mishra, Addl.CIT-DR

Section 139(1)Section 143(1)Section 143(1)(a)Section 36Section 36(1)(va)Section 43B

erred in upholding the prime-facie adjustment to the Returned Income made by Deputy Commissioner of Income Tax, Centralised Processing Center ('CPC') under Section 143(1)(a) of the Act by holding that the same involved only an arithmetic calculation and was within the purview of prima facie adjustments permissible ... under Section 143(1) of the Act. 2. That on the facts and in the circumstances of the case and in law, the Ld. CIT(A) erred in sustaining the adjustment amounting to Rs. 2,19,52,518 to the Returned Income under Section 143(1

Karle Infrastructure Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, CPC, Bangalore

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

ITA 39/BANG/2022[2018-19]Status: DisposedITAT Bangalore21 Mar 2022AY 2018-19

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Smt.Suman Lunkar, CAFor Respondent: Sri.Narayana K.R., Addl.CIT-DR

Section 143(1)Section 143(1)(a)Section 36(1)(va)

IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCHES “C”, BANGALORE Before Shri George George K, JM & Ms.Padmavathy S, AM ITA

S N Balasubramaniya, Bangalore vs. Assistant Commissioner of Income Tax, CPC, Bangalore

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

ITA 60/BANG/2022[2019-20]Status: DisposedITAT Bangalore16 Mar 2022AY 2019-20

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Sri.Sandeep C, CAFor Respondent: Sri.Kannan Narayanan., Addl.CIT-DR

Section 139(1)Section 143(1)Section 143(1)(a)Section 36Section 36(1)(va)Section 43B

Karle Infrastructure Private Limited, Bengaluru vs. Assistant Director of Income Tax, CPC, Bangalore

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

ITA 40/BANG/2022[2019-20]Status: DisposedITAT Bangalore16 Mar 2022AY 2019-20

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am

For Appellant: Smt.Suman Lunkar, CAFor Respondent: Sri.Narayana K.R., Addl.CIT-DR

Section 139(1)Section 143(1)Section 143(1)(a)Section 250Section 36(1)(va)Section 43B

adjustment u/s. 143(1)(a) as done by CPC. The adjustment done by CPC in the intimation being beyond the purview of section 143(1)(a) and the adjustment being not prima facie adjustment should have been deleted by the Commissioner of Income-tax (Appeals) - 11, Bangalore. Instead, the learned