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of <h1>Processing-stage intimation under section 143(1)(a) cannot decide substantial debatable deduction issues; require sections 143(2)/143(3) or reassessment</h1> A high court held that a processing-stage intimation under section 143(1)(a) cannot be used to decide a substantial, debatable legal question concerning deduction entitlement for delayed employee contributions; such issues require scrutiny under sections 143(2)/143(3) or reassessment procedures. Even though a later apex-court ruling resolved the substantive law against the taxpayer, the court found the earlier summary disallowance procedurally infirm because the law was unsettled at the time of processing. The decision set aside the processing-stage disallowance but left the Revenue free to reconsider the claim using appropriate procedures.
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