Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
The ITAT held that adjustments under section 143(1)(a) must be preceded by proper intimation to the assessee, either in writing or electronically, as mandated by the first proviso to section 143(1)(a). In the present case, the assessee was not given any such notice before the CPC made adjustments disallowing the exemption under section 10(10AA)(ii) exceeding Rs. 3 lakhs, based on an invalid Gazette Notification. The Tribunal found this procedural lapse fatal to the validity of the adjustments. Consequently, the appeal was allowed, and the impugned adjustments were set aside for non-compliance with the statutory requirement of prior intimation.
The ITAT held that adjustments under section 143(1)(a) must be preceded by proper intimation to the assessee, either in writing or electronically, as mandated by the first proviso to section 143(1)(a). In the present case, the assessee was not given any such notice before the CPC made adjustments disallowing the exemption under section 10(10AA)(ii) exceeding Rs. 3 lakhs, based on an invalid Gazette Notification. The Tribunal found this procedural lapse fatal to the validity of the adjustments. Consequently, the appeal was allowed, and the impugned adjustments were set aside for non-compliance with the statutory requirement of prior intimation.
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