Limited adjustments under section 143(1) cannot alter returned agricultural income; excess adjustment is rectifiable as an apparent mistake.

In a section 143(1) processing, the Income-tax Officer can make only the limited adjustments expressly permitted by that provision and cannot estimate agricultural income or alter the income returned by the assessee. Such a departure from section 143(1) is treated as a mistake apparent from the record and may be corrected under section 154. Section 143(2)(a) applies only where the processing remains within the section 143(1) framework; it does not justify an adjustment made beyond that scope. The returned agricultural income was therefore required to be restored.

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Issues: Whether, in an assessment made under section 143(1) of the Income-tax Act, 1961, the Income-tax Officer could estimate agricultural income and disturb the income returned by the assessee, and whether such an error could be rectified under section 154 rather than by resort to section 143(2)(a).

Analysis: The assessment under section 143(1) permits only the limited adjustments specifically authorised by that provision. The Income-tax Officer has no authority to go beyond it by estimating income under a head returned by the assessee or by altering the quantum of income disclosed. Such an act is outside the scope of section 143(1) and constitutes a mistake apparent from the record. Section 143(2)(a) is relevant only where the assessment remains within the framework of section 143(1); where the officer travels beyond that provision, the assessee may invoke section 154.

Conclusion: The assessment was liable to be rectified by substituting the agricultural income as returned by the assessee, and the assessee succeeded.

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