Kailash Narayan Shridhar. v. DCIT (2025) 214 ITD 547 (Ahd) (Trib.)

S. 143(1)(a): Assessment-Intimation-Prima facie adjustment Leave encashment-CPC, while processing a return under section 143(1) cannot make any adjustment without issuing any prior intimation as contemplated under the first proviso to section 143(1)(a).[S.10(10AA(ii)]

Assessee, an individual, filed a return of income and subsequently revised it by claiming exemption under section 10(10AA)(ii) in respect of leave encashment received on retirement-CPC processed said return vide an intimation issued under section 143(1) and made an adjustment which resulted in enhancement of income and demand. CIT(A) upheld the adjustment. On appeal, the Tribunal held that   CPC, while processing the return under section 143(1), was not justified in adjusting assessee’s claim of exemption under section 10(10AA)(ii) without issuing any prior intimation as contemplated under the first proviso to section 143(1)(a). Therefore, the intimation issued by CPC under section 143(1) was invalid in law and quashed. (AY. 2022-23)

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