Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
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The ITAT held that an intimation u/s 143(1) is a summary assessment confined to arithmetical and apparent errors, and once scrutiny is initiated and completed u/s 143(3), the earlier 143(1) intimation merges into the regular assessment. In this case, an apparent mistake in the return was brought to CPC through an application u/s 154, and CPC transferred rectification rights to the JAO. The ITAT observed that the JAO, having completed assessment u/s 143(3) without making any adjustment or acting on the rectification application, effectively accepted the returned income. Consequently, sustaining the adjustment proposed earlier by CPC u/s 143(1) was held to be unjustified. The ITAT directed the JAO to rectify the mistake apparent on record and delete the demand raised u/s 143(1), allowing the assessee's appeal.
The ITAT held that an intimation u/s 143(1) is a summary assessment confined to arithmetical and apparent errors, and once scrutiny is initiated and completed u/s 143(3), the earlier 143(1) intimation merges into the regular assessment. In this case, an apparent mistake in the return was brought to CPC through an application u/s 154, and CPC transferred rectification rights to the JAO. The ITAT observed that the JAO, having completed assessment u/s 143(3) without making any adjustment or acting on the rectification application, effectively accepted the returned income. Consequently, sustaining the adjustment proposed earlier by CPC u/s 143(1) was held to be unjustified. The ITAT directed the JAO to rectify the mistake apparent on record and delete the demand raised u/s 143(1), allowing the assessee's appeal.
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