Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
The ITAT held that while CPC/ADIT is empowered to rectify an intimation issued u/s 143(1), any suo motu rectification u/s 154 must mandatorily comply with s.154(3) by issuing prior notice to the assessee. In the present case, CPC passed a rectification order dated 06.04.2022 without serving such notice and incorrectly recorded that the rectification was at the assessee's instance. The ITAT found this to be a jurisdictional defect rendering the rectification order invalid. Consequently, the ITAT set aside the order of the Ld. CIT(A) and directed the AO/CPC to cancel the impugned rectification order. The assessee's appeal was allowed, restoring the original intimation u/s 143(1).
The ITAT held that while CPC/ADIT is empowered to rectify an intimation issued u/s 143(1), any suo motu rectification u/s 154 must mandatorily comply with s.154(3) by issuing prior notice to the assessee. In the present case, CPC passed a rectification order dated 06.04.2022 without serving such notice and incorrectly recorded that the rectification was at the assessee's instance. The ITAT found this to be a jurisdictional defect rendering the rectification order invalid. Consequently, the ITAT set aside the order of the Ld. CIT(A) and directed the AO/CPC to cancel the impugned rectification order. The assessee's appeal was allowed, restoring the original intimation u/s 143(1).
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