Adjustments on debatable/ controversial issues by way of intimation u/s 143(1) is not permissible

360 Realtors LLP Vs ADIT (ITAT Delhi) ITAT Delhi held that amendments to section 36(1)(va) by Finance Act 2021 are retrospective or prospective is debatable and controversial and any adjustments u/s 143(1) of Income Tax Act by way of intimation, on debatable and controversial issues, is beyond the scope of Section 143(1). Facts- The first issue is regarding addition of Rs.58,72,654/- made u/s 36(1)(va) of Income Tax Act, 1961. These payments by way of employees’ contribution to ESI/Provident Fund were deposited by the assessee after the specified date prescribed under the relevant laws gover...