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Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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The Assessing Officer (AO) issued a corrigendum correcting the total income in the original assessment order. The AO has the power to withdraw, modify or substitute an assessment order with another. The corrigendum rectified an error in the preamble of the original assessment order, making it legally valid. The corrected assessment order matched the computation sheet and demand notice accompanying the original order. The Supreme Court's decision in Kalyankumar Ray supports the Revenue's case, as the AO rectified a mistake by issuing the corrigendum, which is a valid assessment order. The CIT(A)'s finding was reversed, and the matter was restored to the CIT(A) for adjudication on merits after allowing the assessee a reasonable opportunity of being heard.
The Assessing Officer (AO) issued a corrigendum correcting the total income in the original assessment order. The AO has the power to withdraw, modify or substitute an assessment order with another. The corrigendum rectified an error in the preamble of the original assessment order, making it legally valid. The corrected assessment order matched the computation sheet and demand notice accompanying the original order. The Supreme Court's decision in Kalyankumar Ray supports the Revenue's case, as the AO rectified a mistake by issuing the corrigendum, which is a valid assessment order. The CIT(A)'s finding was reversed, and the matter was restored to the CIT(A) for adjudication on merits after allowing the assessee a reasonable opportunity of being heard.
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