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Issues: Whether the ICDS-related addition of Rs. 1,284.66 crores made by the Centralized Processing Centre in the intimation under section 143(1)(a) and incorporated in the assessment under section 143(3) ought to be deleted.
Analysis: The intimation issued under section 143(1)(a) incorporated an ICDS adjustment of Rs. 1,284.66 crores which was adopted by the assessing officer in the assessment order under section 143(3). The assessee challenged the intimation before the jurisdictional High Court. The High Court quashed the intimation insofar as it recorded the ICDS adjustment of Rs. 1,284.66 crores. Given that the assessment computation under section 143(3) incorporated the intimation figure, the quashing of the intimation removes the foundational basis for the ICDS addition carried into the assessment. The tribunal directed that consequential modification be made in the assessment computation by deleting the ICDS adjustment; consequential grounds of interest were treated as incidental and left without separate adjudication.
Conclusion: The ICDS-related addition of Rs. 1,284.66 crores made by the CPC in the intimation under section 143(1)(a) and incorporated in the assessment under section 143(3) is to be deleted; the appeal is allowed to that extent in favour of the assessee.
Ratio Decidendi: Where an intimation under section 143(1)(a) is quashed by the High Court for an unauthorized ICDS adjustment, any corresponding incorporation of that adjustment in the assessment under section 143(3) must be modified consequentially by deleting the adjustment.
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