Prior intimation before Section 143(1) adjustment is mandatory; absence of proof invalidates the adjustment.

Section 143(1) permits an adjustment only after the assessee is given prior intimation of the proposed adjustment in writing or electronically. Where the revenue was asked to produce proof of such notice and none was furnished, the adjustment could not be sustained. The assessee therefore succeeded on the ground that the statutory precondition of prior intimation had not been complied with before making the adjustment.

---

---

Issues: Whether an adjustment under Section 143(1) could be sustained when no intimation was given to the assessee before making the adjustment.

Analysis: The statutory scheme of Section 143(1) requires that intimation of the proposed adjustment be given to the assessee in writing or electronically before the adjustment is made. The revenue authorities were directed to produce proof of such notice, but no proof was furnished.

Conclusion: The adjustment could not be sustained in the absence of prior intimation, and the assessee succeeded.

---