https://www.taxtmi.com/caselaws?id=21715 HC held that the ITO exceeded jurisdiction by making extensive prima facie adjustments under s.143(1)(a), effectively rejecting the assessee-company's profit and loss account and recomputing book profits without notice or enquiry. Such disallowances, based on perceived lack of evidence or change of allocation, cannot be made at the intimation stage and must instead be examined through a regular assessment under s.143(2), where the assessee can be heard. Rectification under s.154 cannot cure these substantive errors and does not constitute an efficacious alternative remedy, so a writ under Art. 226 is maintainable. The impugned intimation levying additional tax under s.143(1A) was quashed, and the ITO was directed to process the return afresh strictly in accordance with law. en-us Fri, 07 Feb 1992 00:00:00 +0530 Thu, 11 Dec 2025 14:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21715 HC held that the ITO exceeded jurisdiction by making extensive prima facie adjustments under s.143(1)(a), effectively rejecting the assessee-company's profit and loss account and recomputing book profits without notice or enquiry. Such disallowances, based on perceived lack of evidence or change of allocation, cannot be made at the intimation stage and must instead be examined through a regular assessment under s.143(2), where the assessee can be heard. Rectification under s.154 cannot cure these substantive errors and does not constitute an efficacious alternative remedy, so a writ under Art. 226 is maintainable. The impugned intimation levying additional tax under s.143(1A) was quashed, and the ITO was directed to process the return afresh strictly in accordance with law. Case-Laws Income Tax Fri, 07 Feb 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21715