Prima facie adjustment limits bar disallowance of section 80P deduction in an intimation when the return is timely filed.

The return was filed within the extended due date applicable to the assessee, and the deduction claimed under section 80P(2)(d) could not be disallowed through an intimation under section 143(1). The adjustment mechanism under section 143(1)(a), as applicable for the relevant year, allowed only specified prima facie adjustments and did not extend to this disallowance. As the claim fell outside the permissible scope of adjustment and the return was timely, the disallowance in the intimation was unsustainable.

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Issues: Whether the adjustment disallowing deduction under section 80P(2)(d) could be made in an intimation under section 143(1), and whether the return was filed within the due date.

Analysis: The return was filed within the extended due date applicable to the assessee. The adjustment mechanism under section 143(1)(a), as it stood for the relevant year, permitted only specified prima facie adjustments and did not authorise disallowance of deduction under section 80P. Since the claimed deduction did not fall within the scope of permissible adjustment and the return was within time, the disallowance could not be sustained in the intimation.

Conclusion: The adjustment disallowing deduction under section 80P(2)(d) was unsustainable and was set aside in favour of the assessee.

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