Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
Specified fund definition expands PAN exemption eligibility for registered alternative investment funds and qualifying International Financial Service...
Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
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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