PF/ESI Addition Quashed: CPC Cannot Decide Debatable Issues Under Section 143(1)

A2Z Infra Services Limited Vs DCIT (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi, adjudicated two appeals concerning assessment years 2017–18 and 2019–20 involving disallowance of employees’ and employer’s contributions to Provident Fund (PF) and Employees’ State Insurance (ESI). The primary issue was whether disallowance under Section 36(1)(va) read with Section 2(24)(x) could be made while processing returns under Section 143(1). The assessee contended that, at the time of issuance of intimations under Section 143(1) (dated 28.03.2019 and 07.07.2020), the issue of al...