Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
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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