Section 143(1)(a)(iv) of the Income Tax Act

The decision most relied on for Section 143(1)(a)(iv) is 313 ITR 137 (Bom.); 7. Spectrum Consultants India (P.) Ltd. v. CIT (34 Taxmann.com 20), cited in 228 of the 29 judgments on BharatTax that turn on this section.

Leading authorities on Section 143(1)(a)(iv)

313 ITR 137 (Bom.); 7. Spectrum Consultants India (P.) Ltd. v. CIT
34 Taxmann.com 20 · 2013 · High Court
228
citing judgments
Modern Fibotex India Ltd. v. DCIT
212 ITR 496 · 1995 · High Court
57
citing judgments

Adjustments under Section 143(1)(a) are limited to arithmetical errors or incorrect claims that are prima facie apparent from the information provided in the income tax return itself. The Assessing Officer cannot embark on an inquiry beyond the face of the return during summary assessment proceedings.

Ajmera Housing Corpn v. CIT
326 ITR 642 · 2010 · Supreme Court
47
citing judgments

The scope of proceedings before the Income-tax Settlement Commission under Chapter XIX-A is sui generis, primarily for disclosure and akin to arbitration, and not an appellate forum to examine complex legal disputes.

2017) 250 Taxman 16 (SC) (B)Essae Teraoka (P) Ltd. v. Dy. CIT
266 CTR 246 · 2014 · High Court
28
citing judgments

The Central Processing Centre cannot make adjustments under section 143(1)(a)(iv) that go against a jurisdictional High Court ruling in favour of the assessee, even if the ruling was made after the adjustment.

George Williamson (Assam) Ltd. v. CIT & Anr.
335 ITR 53 · 2011 · High Court
28
citing judgments

Prima facie adjustments under section 143(1)(a) are permissible only for incorrect claims that are apparent from information in the return. Debatable claims cannot be adjusted without giving prior intimation to the assessee.

SYEDA RAHIMUNNISA v. MALAN BI BY L.RS. AND ORS.
10 SCC 315 · 2016 · Reported
27
citing judgments

The High Court, when exercising powers under Section 260A of the Income Tax Act, cannot interfere with a finding of fact unless it is demonstrated to be perverse. This principle is crucial in appeals before the High Court where the existence of a substantial question of law is a prerequisite.

103 Taxman 342/237 ITR 24 (SO; Federation of Andhra Pradesh Chambers of Commerce & Industry v. State of AP
247 ITR 36 · 2001 · Supreme Court
27
citing judgments

Courts must interpret taxing statutes strictly based on the literal wording, disregarding considerations of hardship, injustice, or equity. No room exists for implication or intendment when interpreting tax laws.

Spectrum Consultants v. CIT
266 CTR 94 · 2013 · High Court
27
citing judgments

The Karnataka High Court in Spectrum Consultants v. CIT affirmed the view taken in Essae Teraoka (P.) Ltd. regarding the deductibility of employee contributions to PF and ESI.

Cemetile Industries v. ITO
145 Taxmann.com 209 · 2022 · ITAT
25
citing judgments

Where an assessee-employer deposits the employees' share of contribution towards provident fund and ESI beyond the statutory due dates, disallowance under section 36(1)(va) is justified, and such disallowance is a proper adjustment under section 143(1)(a).

ACIT v. Haryana Telecom Pvt. Ltd.
14 Taxmann.com 122 · 2009 · High Court
23
citing judgments

Judgments on Section 143(1)(a)(iv)

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