Section 143(1)(a)(iv) of the Income Tax Act
Income-tax Act, 2025: s.270
Section 143(1)(a)(iv) falls under section 143 of the Income-tax Act, 1961, which corresponds to section 270 (Assessment) of the Income-tax Act, 2025.
Read section 270 of the 2025 Act
Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.
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 69 judgments on BharatTax that turn on this section.
Leading authorities on Section 143(1)(a)(iv)
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.
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.
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.
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.
Courts and Tribunals cannot grant relief beyond statutory provisions.
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.
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).
An Assessing Officer lacks the power under Section 143(1)(a) to make prima facie adjustments of a controversial nature, as doing so can amount to overstepping jurisdiction and incorrectly determining income.
