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Section 143 (1)(a) of the Income-tax Act, 1961 - Assessment - Prima facie adjustment - Assessment years 1984-85 and 1985-86 Illustrations [In favour of revenue] Where assessee made belated claim of investment allowance relating to assessment years 1984-85 and 1985-86 in the return filed for 1994-95, the claim was prima facie inadmissible because it was obviously beyond the period of limitation provided under the Act. Further, where the assessee had claimed prior period expenses and the assessee had not shown in the return and annexures as to the provision under which claim of deduction was made, the items were prima facie not admissible under the Act, disallowance thereof under section 143(1)(a) was justified. P.K.R. Menon and Jose Joseph for the Appellant. P. Balakrishnan for the Respondent. JUDGMENT C.N. Ramachandran Nair, J.-The question raised in the appeal filed by the Revenue is whether the Tribunal was justified in cancelling the assessment made under section 143(1)(a) for the reason that disallowances made do not fall within the description "prima facie inadmissible items". After hearing both sides and after going through the proceedings issued under section 143(1)(a) and the order of the Tribunal, we are unable to uphold the order of the Tribunal for more than one reason. In the first place, against proceedings under section 143(1)(a) the assessee itself filed rectification application under section 154 which goes to prove that the assessee was satisfied that the proceedings issued under section 143(1)(a) with additions contained only mistakes. In our view, the assessee…

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