Intimation under Section 143(1) cannot be issued after 9 months from the end of the FY in which the return is filed: ITAT
A recent ITAT Delhi decision clarifies that intimation under Section 143(1) must be sent within the limitation period prescribed by law. In ITA No. 4780/Del/2024 (BPTP Limited v. DCIT, AY 2021-22), the Tribunal held that CPC’s intimation, issued after expiry of 9 months from the end of the financial year in which the return was filed, is barred by the fifth proviso to Section 143(1) and therefore invalid. All adjustments made in post-limitation intimations stand deleted. This order will have significant implications for taxpayers receiving intimation after statutory time limits—such actions are unsustainable in law.
Key Points for Tax Professionals
• Intimation under Section 143(1) cannot be issued after 9 months from the end of the FY in which the return is filed, per recent ITAT ruling.
• Adjustments made via intimation sent beyond this period are not legally valid and should be challenged.
• The judgment reinforces the importance of limitation periods in tax administration and taxpayer rights.
The copy of the order is as under
 cannot be issued after 9 months from the end of the FY in which the return is filed: ITAT){kind=link}
 cannot be issued after 9 months from the end of the FY in which the return is filed: ITAT&description=&image=https://thetaxtalk.com/wp-content/uploads/2025/11/Slide8.jpg){kind=link}