Rectification remedy for section 143(1)(a) disallowances stayed tax recovery pending final administrative consideration.

Intimations under section 143(1)(a) of the Income-tax Act that make disallowances without prior opportunity may be challenged through rectification, and the taxpayer was directed to invoke section 154(1)(b) within two weeks. The revenue authority was required to consider the rectification application and pass a final order within three weeks, while recovery of the enhanced tax was stayed until then. The document reflects that the immediate procedural remedy was rectification pending final administrative consideration.

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Issues: Whether the intimations issued under section 143(1)(a) of the Income-tax Act, 1961, effecting disallowances without opportunity, should be interfered with and whether the petitioner should be permitted to seek rectification under section 154(1)(b) pending final consideration.

Outcome: The petitioner was directed to file a rectification application under section 154(1)(b) within two weeks, the revenue authority was directed to consider it and pass final orders within three weeks, and recovery of the enhanced tax was stayed in the meantime.

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