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“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)

The Salesian Sisters, Kolkata vs. ITO, Ward 1(3), Exempt, Kolkata

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

ITA 576/KOL/2025[2018-2019]Status: DisposedITAT Kolkata27 Oct 2025AY 2018-2019

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 11(2)Section 11(3)Section 12ASection 143(1)Section 143(1)(a)Section 143(3)Section 250Section 264

IN THE INCOME TAX APPELLATE TRIBUNAL KOLKATA ‘D’ BENCH, KOLKATA Before SHRI GEORGE MATHAN, JUDICIAL MEMBER & SHRI RAKESH MISHRA, ACCOUNTANT

Addl CIT Sp RG 22, Mumbai vs. Dsp Merrill Lynch Ltd, Mumbai

In the result, appeal of the assessee is partly allowed and the appeal of the revenue is dismissed

ITA 2198/MUM/2011[1994-95]Status: DisposedITAT Mumbai27 Oct 2025AY 1994-95

Bench: Shri Amit Shukla, Jm& Ms Padmavathy S, Am

For Appellant: Shri Nitesh JoshiFor Respondent: Shri. Leyaqat Ali Aafaqui, Sr. AR
Section 140ASection 143(1)(a)Section 143(3)Section 147Section 234Section 234BSection 234B(3)Section 250Section 80Section 800

interest under section 234B of the Act ought to be levied only for the period from the date of passing of Intimation under section 143(1)(a) of the Act to the date of passing of the order under section 143(3) rw.s

Dsp Merrill Lynch Limited, Mumbai vs. Addl C.I.T. Range 4(1), Mumbai

In the result, appeal of the assessee is partly allowed and the appeal of the revenue is dismissed

ITA 1581/MUM/2011[1994-95]Status: DisposedITAT Mumbai27 Oct 2025AY 1994-95

Bench: Shri Amit Shukla, Jm& Ms Padmavathy S, Am

For Appellant: Shri Nitesh JoshiFor Respondent: Shri. Leyaqat Ali Aafaqui, Sr. AR
Section 140ASection 143(1)(a)Section 143(3)Section 147Section 234Section 234BSection 234B(3)Section 250Section 80Section 800

interest under section 234B of the Act ought to be levied only for the period from the date of passing of Intimation under section 143(1)(a) of the Act to the date of passing of the order under section 143(3) rw.s

Security Printing and Mintingcorporation of India Ltd, New Delhi vs. ACIT, Circle 22(2), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 1665/DEL/2023[2018-19]Status: DisposedITAT Delhi27 Oct 2025AY 2018-19

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Y.K. Meghan, CAFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 139(1)Section 143(1)Section 14ASection 234Section 40ASection 43B

Security Printing Vs. ACIT The Ld. CIT (A) issued directions to Ld. AO to verify facts and decide as per provisions of section 143(1). a) Without prejudice to ground no (v) above, the Ld. CIT (A) has erred in law on the facts and in the circumstances ... made in the intimation u/s. 143(1) of the Act on a finding that such disallowance is beyond the scope of section 143(1)(a) of the Act, albeit the Tribunal noted that it is conscious of the fact that the issue on merits is decided against the assessee

Chithalpadi Pacs Ltd., Dharmapuri vs. ITO, Ward-1, Dharmapuri

In the result, both the appeals filed by the assessee are dismissed

ITA 1788/CHNY/2025[2022-23]Status: DisposedITAT Chennai24 Oct 2025AY 2022-23

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. Nos.1787 & 1788/Chny/2025 िनधा"रण वष"/Assessment Year: 2021-22 & 2022-23 Chinthalpadi Primary Agri. Co-Operative Vs. The Income Tax Officer, Society Limited, Chinthalpadi Village, Ward 1, Chinthalpadi Post, Pappireddipatty Tk, Dharmapuri. Dharmapuri 635 302. [Pan:Aaaac9429J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Dr. M. Mohan Babu, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 09.10.2025 घोषणा की तारीख /Date Of Pronouncement : 24.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Both Dated 24.03.2025 Passed By The Addl./Jcit(A)-3, Ahmedabad For The Assessment Years 2021-22 & 2022-23. 2. Since Issues Raised In Both The Appeals Of The Assessee Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To Hear The Appeals Together & Pass Consolidated Order For The Sake Of Convenience.

For Appellant: NoneFor Respondent: Dr. M. Mohan Babu, Addl. CIT
Section 139Section 139(1)Section 143(1)Section 80Section 80ASection 80PSection 80P(2)

income as NIL after claiming deduction under section 80P(2) of the Act of ₹.2,59,542/-. The CPC, Bengaluru passed intimation under section 143(1) of the Act dated 13.12.2024 disallowing the claim of deduction under section 80P(2) of the Act. The ld. CIT(A) upheld the order

Chinthalpadi Pacs Ltd., Dharmapuri vs. ITO, Ward-1, Dharmapuri

In the result, both the appeals filed by the assessee are dismissed

ITA 1787/CHNY/2025[2021-22]Status: DisposedITAT Chennai24 Oct 2025AY 2021-22

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. Nos.1787 & 1788/Chny/2025 िनधा"रण वष"/Assessment Year: 2021-22 & 2022-23 Chinthalpadi Primary Agri. Co-Operative Vs. The Income Tax Officer, Society Limited, Chinthalpadi Village, Ward 1, Chinthalpadi Post, Pappireddipatty Tk, Dharmapuri. Dharmapuri 635 302. [Pan:Aaaac9429J] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Dr. M. Mohan Babu, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 09.10.2025 घोषणा की तारीख /Date Of Pronouncement : 24.10.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: Both The Appeals Filed By The Assessee Are Directed Against Separate Orders Both Dated 24.03.2025 Passed By The Addl./Jcit(A)-3, Ahmedabad For The Assessment Years 2021-22 & 2022-23. 2. Since Issues Raised In Both The Appeals Of The Assessee Are Similar Based On The Same Identical Facts, With The Consent Of Both The Parties, We Proceed To Hear The Appeals Together & Pass Consolidated Order For The Sake Of Convenience.

For Appellant: NoneFor Respondent: Dr. M. Mohan Babu, Addl. CIT
Section 139Section 139(1)Section 143(1)Section 80Section 80ASection 80PSection 80P(2)

income as NIL after claiming deduction under section 80P(2) of the Act of ₹.2,59,542/-. The CPC, Bengaluru passed intimation under section 143(1) of the Act dated 13.12.2024 disallowing the claim of deduction under section 80P(2) of the Act. The ld. CIT(A) upheld the order

Yuvak Pratishthan, Mumbai vs. ITO Exem Ward 2(4), Mumbai

ITA 3347/MUM/2025[2023-24]Status: DisposedITAT Mumbai22 Oct 2025AY 2023-24

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Ms. Kinjal Bhuta- Advocate
Section 11Section 11(3)Section 115BSection 12ASection 143Section 143(1)Section 143(1)(a)Section 250

Form No. 10BB in other cases. 3. The return of the assessee was processed and the an adjustment notices was issued under section 143(1)(a)(ii) stating that since the total income of the assessee exceed to Rs. 5 crore the Audit Report should have been filed in Form ... regard to the mismatch and the assessee responded on 03.12.2024 stating that the figure was mentioned mistakenly. The CPC however issued intimation under section 143(1) on 20.12.2024 making an addition of Rs. 57,21,300/- over and above the income declared by the assessee under section 115BBI

Dipak Kumar Hazra, Howrah vs. ITO, Ward 47(2), Kolkata

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

ITA 1135/KOL/2025[2018-2019]Status: DisposedITAT Kolkata21 Oct 2025AY 2018-2019

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 143(1)Section 143(1)(a)Section 250Section 43B

Bombay High Court, reported in 156 ITR 55 in support of the claim that debatable issue could not have been disallowed under section 143(1)(a) of the Act. 6. We have heard the submissions made. Similar issue came up before the Bench in the case of DCIT vs. Seven

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Tiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1655/CHNY/2025[2021-22]Status: DisposedITAT Chennai21 Oct 2025AY 2021-22

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

among them is that the income assessed is greater than the income tax return processed under clause (a) of sub section (1) of section 143(1) of the Act. In simple term, the clause deals with the situation that result in addition in assessments. 6.5.3 The question of misreporting will ... papers and Assessing Officer completed assessment by accepting said LTCG, since income assessed was not greater than income determined in return processed under section 143(1)(a),there was no case of under reporting of income as per provisions of section 270A(2)and (3) and, thus, penalty under section

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Thiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1654/CHNY/2025[2020-21]Status: DisposedITAT Chennai21 Oct 2025AY 2020-21

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

among them is that the income assessed is greater than the income tax return processed under clause (a) of sub section (1) of section 143(1) of the Act. In simple term, the clause deals with the situation that result in addition in assessments. 6.5.3 The question of misreporting will ... papers and Assessing Officer completed assessment by accepting said LTCG, since income assessed was not greater than income determined in return processed under section 143(1)(a),there was no case of under reporting of income as per provisions of section 270A(2)and (3) and, thus, penalty under section

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Thiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1653/CHNY/2025[2019-20]Status: DisposedITAT Chennai21 Oct 2025AY 2019-20

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

among them is that the income assessed is greater than the income tax return processed under clause (a) of sub section (1) of section 143(1) of the Act. In simple term, the clause deals with the situation that result in addition in assessments. 6.5.3 The question of misreporting will ... papers and Assessing Officer completed assessment by accepting said LTCG, since income assessed was not greater than income determined in return processed under section 143(1)(a),there was no case of under reporting of income as per provisions of section 270A(2)and (3) and, thus, penalty under section

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Tiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1652/CHNY/2025[2018-19]Status: DisposedITAT Chennai21 Oct 2025AY 2018-19

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

among them is that the income assessed is greater than the income tax return processed under clause (a) of sub section (1) of section 143(1) of the Act. In simple term, the clause deals with the situation that result in addition in assessments. 6.5.3 The question of misreporting will ... papers and Assessing Officer completed assessment by accepting said LTCG, since income assessed was not greater than income determined in return processed under section 143(1)(a),there was no case of under reporting of income as per provisions of section 270A(2)and (3) and, thus, penalty under section

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Tiruvannamalai

In the result, all the six appeals of the Revenue are

ITA 1651/CHNY/2025[2017-18]Status: DisposedITAT Chennai21 Oct 2025AY 2017-18

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

among them is that the income assessed is greater than the income tax return processed under clause (a) of sub section (1) of section 143(1) of the Act. In simple term, the clause deals with the situation that result in addition in assessments. 6.5.3 The question of misreporting will ... papers and Assessing Officer completed assessment by accepting said LTCG, since income assessed was not greater than income determined in return processed under section 143(1)(a),there was no case of under reporting of income as per provisions of section 270A(2)and (3) and, thus, penalty under section

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Ethirajulu Vajravel Kumaran, Chennai

In the result, all the six appeals of the Revenue are

ITA 1650/CHNY/2025[2015-16]Status: DisposedITAT Chennai21 Oct 2025AY 2015-16

Bench: Shri George George K & Shri S.R. Raghunatha

For Appellant: Shri Shiva Srinivas, CITFor Respondent: Shri R. Venkata Raman, CA
Section 1Section 132Section 139(1)Section 14Section 143(3)Section 153ASection 250Section 271(1)(c)

among them is that the income assessed is greater than the income tax return processed under clause (a) of sub section (1) of section 143(1) of the Act. In simple term, the clause deals with the situation that result in addition in assessments. 6.5.3 The question of misreporting will ... papers and Assessing Officer completed assessment by accepting said LTCG, since income assessed was not greater than income determined in return processed under section 143(1)(a),there was no case of under reporting of income as per provisions of section 270A(2)and (3) and, thus, penalty under section

Netflix Entertainment Services India LLP, Mumbai vs. Deputy Commissioner of Income Tax- Circle 23(1), Mumbai

In the result, appeal of the assessee is partly

ITA 6857/MUM/2024[2021-22]Status: DisposedITAT Mumbai17 Oct 2025AY 2021-22
Section 143(3)Section 144C(5)Section 234ASection 270ASection 40

contended that there is an error in computation of assessed income which has been stated that as per the intimation issued under section 143(1) of the Act, no adjustment was made to the returned income of INR 27,63,46,470. However, the assessment order incorrectly mentions the income ... computed under section 143(1)(a) of the Act as INR 29,63,00,220 to which the adjustments made in assessment order (of INR 4,44,95,50,224) are added, to take the assessed income to INR 474,58,50,440 (instead

Capup Online Services Pvt Ltd, Bangalore vs. Income Tax Officer, Ward-2(2)(1), Bangalore

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 422/BANG/2025[2023-24]Status: DisposedITAT Bangalore16 Oct 2025AY 2023-24

Bench: Shri Waseem Ahmed & Shri Soundararajan Kassessment Year: 2023-24

For Appellant: Shri Rohit Goutamchand, CAFor Respondent: Dr. Thejaswi GV, JCIT
Section 115BSection 143Section 143(1)Section 143(1)(a)Section 44ASection 80I

only issue raised by the assessee is that the learned CIT-A erred in confirming the disallowance made by the CPC under section 143 (1) of the act by denying the deduction u/s 80IAC of the Act. Page 2 of 5 3. The CPC, Bengaluru, while issuing intimation u/s 143 ... applying provisions of Section 115BAA since MAT provisions were also attracted, and once so applied, Chapter VI-A deductions are not available. Section 143(1)(a) permits CPC to disallow claims not admissible on the face of the return, and the disallowance of deduction u/s 80IAC was within such power

Sri Shyambaba Electronic Pvt Ltd, Hyderabad vs. DCIT., Circle-3(1), Hyderabad

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 453/HYD/2024[2021-22]Status: DisposedITAT Hyderabad15 Oct 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.453/Hyd/2024 िनधा"रण वष"/Assessment Year 2021-2022 Sri Shyambaba Electronic The Dcit, Pvt. Ltd., Hyderabad. Vs. Circle-3(1), Pin – 500 012. Telangana. Hyderabad. Pan Aaxcs1651F (Appellant) (Respondent) िनधा"रती "ारा/Assessee By: Ca A Srinivas राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 07.10.2025 घोषणा की तारीख/Pronouncement: 15.10.2025 आदेश/Order Per Vijay Pal Rao: This Appeal By The Assessee Is Directed Against The Order Dated 11.03.2024 Of The Learned Cit(A)-National Faceless Appeal Centre [In Short “Nfac], Delhi, For The Assessment Year 2021-2022. 2

For Appellant: CA A SrinivasFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 143(3)

आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad "ी "वजय पाल राव

Sunil Gangadhar Karve, Mumbai vs. Dy CIT Circle 16(3), Mumbai

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

ITA 2619/MUM/2025[2021-22]Status: DisposedITAT Mumbai15 Oct 2025AY 2021-22

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhan

Section 143(1)Section 23Section 250Section 71B

from house property" though the said adjustment is not covered within the purview of sub-clause (i) to (vi) of clause (a) of section 143(1) of the Act. 4. Ld. CIT(A) observed that despite several opportunities provided to the assessee, the assessee utterly failed to adduce any clinching ... order without giving sufficient opportunity to the assessee to submit the documents and confirmed the intimation order without following the provision of section 143(1) of the Act as adjustment has been made without intimating of the said adjustment, hence adjustment is not legally sustainable in the eyes

DCIT, Circle 4(2), New Delhi vs. M/S Cnh Industrial (India) Pvt Ltd, Uttar Pradesh

In the result, the appeal of the Revenue in ITA No

ITA 305/DEL/2025[2023-24]Status: DisposedITAT Delhi15 Oct 2025AY 2023-24

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Shrikant Namdeo, CIT-DR
Section 139(1)Section 143(1)Section 143(1)(a)

Page 1 of 5 ITA No. 305/DEL/2025 [A.Y. 2023-24] CNH Industrial Ltd Vs. Dy. CIT Center(CPC) in the intimation order under Section 143(1) of the Income Tax Act, 1961 dated 03.05.2024, without remanding the matter back to the Assessing Officer (AO) for Verification. 2. Whether the Learned ... grievance dated 21.03.2024 and stated the reasons why proposed adjustment should not be made. Subsequently, the return of income was processed under section 143(1) of the Act and intimation dated 03.05.2024 was issued by the Deputy Director of Income Tax, CPC, Bangalore without considering the grievance filed

Ganganager Vehicles Pvt. Ltd, Delhi vs. ITO, Ward-10(1), New Delhi

In the result, appeals of assessee in ITA Nos

ITA 991/DEL/2024[2021-22]Status: DisposedITAT Delhi15 Oct 2025AY 2021-22

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Pratap Gupta, CAFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 143(1)Section 143(1)(a)Section 143(3)Section 36(1)(va)

made in the intimation u/s. 143(1) of the Act on a finding that such disallowance is beyond the scope of section 143(1)(a) of the Act, albeit the Tribunal noted that it is conscious of the fact that the issue on merits is decided against the assessee ... proceedings whether it is scrutiny assessment under Section 143(3) of the IT Act or the proceeding of processing tax return under Section 143(1) of the IT Act. Following the above decision, we hold that the adjustment u/s 143(1) made on account of delayed payment of PF/ESIC