#Section 143(1)(a)

The ITAT Delhi has ruled that tax authorities cannot impose disallowances under Section 143(1)(a) for contributions to welfare funds if the legal position under Section 36(1)(va) was unsettled at the time of the intimation. This protects assessees from automatic adjustments when judicial clarity is pending, reinforcing procedural fairness in summary assessments and benefiting all taxpayers facing ambiguous statutory interpretations.

Chhattisgarh High Court rules that prima facie adjustments under Section 143(1)(a) of the Income Tax Act cannot resolve legally debatable issues, particularly when the matter is pending judicial resolution. The court set aside a disallowance of ₹4.64 lakh under Section 36(1)(va), emphasizing that summary proceedings cannot override substantive legal disputes.