Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Addition by way of adjustment u/s 143(1) by CPC - Procedure - Unlike the old scheme of ‘prima facie adjustments’ u/s 143(1)(a), the scheme of present section 143(1) does not involve a unilateral exercise. The very fact that an opportunity of the assessee being provided with an intimation of 'such adjustments' [as proposed u/s143(1)], in writing or by electronic mode, and "the response received from the assessee, if any" to be "considered before making any adjustment" makes the process of making adjustments u/s 143(1), under the present legal position, an interactive and cerebral process. - CPC has to dispose of the objections before proceeding further - AT
Addition by way of adjustment u/s 143(1) by CPC - Procedure - Unlike the old scheme of ‘prima facie adjustments’ u/s 143(1)(a), the scheme of present section 143(1) does not involve a unilateral exercise. The very fact that an opportunity of the assessee being provided with an intimation of 'such adjustments' [as proposed u/s143(1)], in writing or by electronic mode, and "the response received from the assessee, if any" to be "considered before making any adjustment" makes the process of making adjustments u/s 143(1), under the present legal position, an interactive and cerebral process. - CPC has to dispose of the objections before proceeding further - AT
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