143(1) Intimation Beyond 9-Month Limit Void – ITAT Quashes CPC’s Adjustment

BPTP Limited Vs DCIT (ITAT Delhi) Assessee filed appeal against the order of CIT(A), which upheld intimation u/s 143(1) issued by CPC, Bangalore. The principal issue was whether the intimation dated 27.02.2023 was barred by limitation as per the fifth proviso to section 143(1). Assessee filed its return of income for AY 2021-22 on 15.03.2022. Under the proviso to section 143(1), no intimation can be issued after expiry of nine months from the end of the financial year in which the return is made. Therefore, the statutory limitation for sending intimation expired on 31.12.2022. Assessee produce...