Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
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Validity of adjustments made in an intimation u/s 143(1) of the Income Tax Act, where there was a mismatch between the income tax return and the tax audit report filed by the assessee. The key issue was whether the Centralized Processing Centre (CPC) could make adjustments u/s 143(1)(a) while processing the return without complying with the first proviso, which requires prior intimation to the assessee. The Tribunal held that any proposed adjustment necessitates prior intimation to the assessee, either in writing or electronically, as per the first proviso to Section 143(1)(a). The CPC failed to issue such prior intimation before making the adjustment. Consequently, the impugned intimation issued u/s 143(1)(a) was not in compliance with the provisos and was deemed invalid under the Act. The assessee's appeal was allowed.
Validity of adjustments made in an intimation u/s 143(1) of the Income Tax Act, where there was a mismatch between the income tax return and the tax audit report filed by the assessee. The key issue was whether the Centralized Processing Centre (CPC) could make adjustments u/s 143(1)(a) while processing the return without complying with the first proviso, which requires prior intimation to the assessee. The Tribunal held that any proposed adjustment necessitates prior intimation to the assessee, either in writing or electronically, as per the first proviso to Section 143(1)(a). The CPC failed to issue such prior intimation before making the adjustment. Consequently, the impugned intimation issued u/s 143(1)(a) was not in compliance with the provisos and was deemed invalid under the Act. The assessee's appeal was allowed.
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