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Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
The dominant issue was whether an intimation under s.143(1)(a), which made adjustments by disallowing deduction under s.35(1) and denying MAT credit, merged into the subsequent regular assessment under s.143(3), thereby foreclosing consideration of the assessee's rectification application under s.154. The Tribunal held that merger was not attracted because the AO, while completing the s.143(3) assessment, merely adopted the income as per the s.143(1)(a) intimation without adjudicating the assessee's specific grievances raised in the s.154 application. Consequently, the matter was remanded to the first appellate authority to decide the objections afresh, and the appeal was allowed for statistical purposes. - ITAT
The dominant issue was whether an intimation under s.143(1)(a), which made adjustments by disallowing deduction under s.35(1) and denying MAT credit, merged into the subsequent regular assessment under s.143(3), thereby foreclosing consideration of the assessee's rectification application under s.154. The Tribunal held that merger was not attracted because the AO, while completing the s.143(3) assessment, merely adopted the income as per the s.143(1)(a) intimation without adjudicating the assessee's specific grievances raised in the s.154 application. Consequently, the matter was remanded to the first appellate authority to decide the objections afresh, and the appeal was allowed for statistical purposes. - ITAT
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