Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
Section 143(1)(a) permits only summary adjustments apparent from the return, not resolution of a debatable deduction issue. On the date of intimation, whether employees' contribution to ESI and EPF deposited after the due date under the labour laws but before filing the return was allowable was already subject to conflicting judicial views. The disclosed delay in the audit report did not make the disallowance self-evident, and the Assessing Officer could not treat the claim as a prima facie adjustment. The intimation and appellate orders were set aside, with liberty to the Revenue to proceed by regular assessment in accordance with law.
Section 143(1)(a) permits only summary adjustments apparent from the return, not resolution of a debatable deduction issue. On the date of intimation, whether employees' contribution to ESI and EPF deposited after the due date under the labour laws but before filing the return was allowable was already subject to conflicting judicial views. The disclosed delay in the audit report did not make the disallowance self-evident, and the Assessing Officer could not treat the claim as a prima facie adjustment. The intimation and appellate orders were set aside, with liberty to the Revenue to proceed by regular assessment in accordance with law.
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