Adjustments by section 143(1) intimation on debatable issues not permissible

Prowiz Mansystems Private Limited Vs DCIT (ITAT Delhi) Facts- The addition in dispute in this appeal is regarding the additions amounting to total of Rs.3,97,41,559/- made u/s 36(1)(va) of Income Tax Act. 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 governing ESI and Provident Fund. However, payments were deposited by the assessee well before due date of filing of return of income under Section 139(1) of Income Tax Act. The aforesaid additions totaling Rs.3,97,41,559/- were ma...