Debatable depreciation claim cannot be disallowed through summary processing under section 143(1)(a) when rival views are possible.

A depreciation claim could not be summarily disallowed as a prima facie adjustment under section 143(1)(a) because the issue was debatable and required scrutiny beyond summary processing. The Tribunal treated the materials as showing that different views were possible on the claim, so the adjustment in the intimation was not justified. It also left undisturbed the order of the first appellate authority, with the result that the summary adjustment was held impermissible and the rectification challenge did not succeed.

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Issues: Whether the adjustment made in the intimation under section 143(1)(a) of the Income-tax Act, 1961, in respect of the assessee's depreciation claim could be sustained, and whether the assessee's application for rectification under section 154 of the Income-tax Act, 1961 was rightly rejected.

Analysis: The dispute turned on whether the depreciation claim involved a matter capable of being adjusted summarily or whether it raised a debatable question requiring scrutiny under section 143(2) of the Income-tax Act, 1961. The Tribunal noted that the claim could not be treated as a straightforward prima facie disallowance under section 143(1)(a), and that the materials relied upon showed the issue to be one on which different views were possible. Although the lower appellate authority had not given reasons in full, the Tribunal found that the adjustment itself was not warranted under the summary processing provision.

Conclusion: The adjustment was not permissible under section 143(1)(a) of the Income-tax Act, 1961, and the order of the first appellate authority was not interfered with.

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