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Issues: Whether the adjustment made while processing the return under section 143(1)(a)(ii) to restrict the assessee's leave encashment exemption under section 10(10AA) was legally sustainable.
Analysis: The adjustment under section 143(1)(a)(ii) is confined to cases of an apparent incorrect claim from the return or accompanying material. The dispute here did not involve a patent arithmetical error or a clear mismatch disclosed in the return, but turned on the applicability of the exemption claim itself. Such a controversy could not be resolved by summary adjustment in processing under section 143(1). The lower authorities therefore exceeded the permissible scope of processing while limiting the exemption to Rs. 3 lakhs.
Conclusion: The restriction of the leave encashment exemption under section 143(1)(a)(ii) was unsustainable and the assessee succeeded on this issue.
Ratio Decidendi: A summary adjustment under section 143(1)(a)(ii) cannot be used to disallow an exemption claim where the issue requires substantive examination rather than correction of an apparent error from the return.