Prima facie adjustment for delayed PF/ESIC contribution upheld, but factual dispute on due-date computation was remanded for verification.

Disallowance of employees' PF/ESIC contribution was treated as a permissible prima facie adjustment under section 143(1)(a), and the assessee's challenge on that point was rejected because delayed deposit fell within the processing mechanism. The alternative contention on how the statutory due date should be computed, including whether it should be linked to the month of actual salary disbursement, involved unresolved facts and was restored for fresh verification. The assessee therefore succeeded only to the limited extent of remand on that factual issue, while the primary objection to the adjustment failed.

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Issues: (i) whether the disallowance of employees' contribution to PF/ESIC could be made as a prima facie adjustment under section 143(1)(a); (ii) whether the alternative plea on the computation of the due date for deposit of employees' contribution required remand for factual verification.

Issue (i): whether the disallowance of employees' contribution to PF/ESIC could be made as a prima facie adjustment under section 143(1)(a).

Analysis: The challenge on this aspect was treated as settled against the assessee. The adjustment relating to delayed deposit of employees' contribution was held to fall within the scope of the processing mechanism, and the contrary line of authorities relied upon by the assessee was treated as already distinguished by coordinate benches.

Conclusion: The issue was decided against the assessee.

Issue (ii): whether the alternative plea on the computation of the due date for deposit of employees' contribution required remand for factual verification.

Analysis: The alternative contention concerned the factual method of determining the relevant month for deposit, namely whether the due date should be linked to the month of actual salary disbursement. As this aspect had not been examined on facts by the Assessing Officer, the matter was restored for fresh consideration after giving the assessee an opportunity to place the relevant material.

Conclusion: The issue was decided in favour of the assessee to the extent of remand.

Final Conclusion: The assessee succeeded only on the limited ground of remand for reconsideration of the alternative plea, while the primary objection to the adjustment was rejected.

Ratio Decidendi: A factual controversy bearing on the computation of the statutory due date for employees' contribution may warrant remand for verification, but a belated deposit covered by the processing provisions cannot be excluded from prima facie adjustment merely by invoking a general deduction provision.

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