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Issues: Whether the disallowance of expenditure in the intimation issued under Section 143(1) of the Income-tax Act, 1961 was a permissible adjustment and whether the intimation was liable to be quashed.
Analysis: The adjustment made in the processing of the return went beyond the limited scope of Section 143(1) of the Income-tax Act, 1961. The fact that the assessee had filed an incorrect return did not authorise the CPC to make a substantive disallowance of expenditure at the intimation stage. The order also treated the impugned intimation as unsustainable in law.
Conclusion: The adjustment was impermissible and the intimation was quashed in favour of the assessee.