Held that clause (iv) of section 143(1)(a) talks of two different limbs, namely, ‘disallowance of expenditure’ and ‘increase in income’ by means of indication in audit report, both limbs are independent of each other. Adjustment under section 143(1)(a) by means of disallowance made for late deposit of employees’ share to relevant funds beyond date prescribed under respective Acts, was a case of ‘disallowance of expenditure’ and not ‘increase of income’ and thus same was valid. Followed Checkmate Services (P) Ltd .v. CIT (2022) 448 ITR 518 (SC) (AY. 2017-18 to 2020-21)
Cemetile Industries. v. ITO (2022) 220 DTR 265 / 220 TTJ 801 / (2023) 198 ITD 322 (Pune) (Trib.) Late Dhannang Shankar Ganesh v. Dy.CIT (2022) 220 DTR 313 / 220 TTJ 813 (Chennai)(Trib)
S. 143(1) : Assessment-Intimation-Prima facie adjustment Employees contribution to EPF/ESI-Adjustment is held to be valid [S. 36(1)(va), 43B, 143(1)(a)]