Section 143(1)(a) adjustments cannot disallow provident fund and ESI payments made before the return-filing deadline.

Adjustment under section 143(1)(a) is confined to the specific categories authorised by the statute, and the assessee's response must be considered before any disallowance is made. A reasoned order is required because the CPC acts in a quasi-judicial capacity while processing returns. The Finance Act, 2021 amendment concerning employees' contribution under section 36(1)(va) was held to apply prospectively, so the pre-amendment position continued to govern the year in question. On that basis, provident fund and ESI contributions paid before the due date for filing the return under section 139(1) could not be disallowed merely because they were deposited after the welfare-law due date; the adjustment was deleted.

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Issues: Whether employees' contribution to provident fund and ESI, paid after the due date under the respective welfare statutes but before the due date for filing the return under section 139(1), could be disallowed as an adjustment under section 143(1)(a), and whether the amendment inserted by the Finance Act, 2021 applied retrospectively.

Analysis: The scope of adjustment under section 143(1)(a) is limited to the categories expressly permitted by the statute and the response of the assessee must be considered before making any adjustment. The order disposing of objections must be reasoned, because the CPC performs a quasi-judicial function while processing the return. A tax audit report is only an opinion of an professional and cannot override the binding law declared by the jurisdictional High Court. The amendment relating to employees' contribution under section 36(1)(va), inserted by the Finance Act, 2021, was held to operate prospectively, so the pre-amendment legal position continued to apply for the year in question. Under that position, payments made before the due date under section 139(1) could not be disallowed merely because they were deposited after the due date under the welfare statutes.

Conclusion: The adjustment made under section 143(1)(a) was not sustainable, and the disallowance was deleted in favour of the assessee.

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