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    <title>2025 (12) TMI 1113 - BOMBAY HIGH COURT</title>
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    <description>Whether deduction under s.10B could be disallowed by a prima facie adjustment in an intimation under s.143(1) was the dominant issue. The HC held that where the allowability and computation of s.10B deduction is a debatable matter requiring examination of factual/legal records, it cannot be subjected to adverse adjustment under s.143(1), consistent with prior HC authority that debatable issues are outside the scope of such adjustments; accordingly, the impugned s.143(1) adjustment was quashed. The HC further held that the rectification order was barred by limitation under s.154(6) and s.154(7), rendering it null and void; consequently, the Revenue was directed to refund the adjusted amounts with applicable interest within 8 weeks.</description>
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    <pubDate>Tue, 02 Dec 2025 00:00:00 +0530</pubDate>
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      <title>2025 (12) TMI 1113 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=783573</link>
      <description>Whether deduction under s.10B could be disallowed by a prima facie adjustment in an intimation under s.143(1) was the dominant issue. The HC held that where the allowability and computation of s.10B deduction is a debatable matter requiring examination of factual/legal records, it cannot be subjected to adverse adjustment under s.143(1), consistent with prior HC authority that debatable issues are outside the scope of such adjustments; accordingly, the impugned s.143(1) adjustment was quashed. The HC further held that the rectification order was barred by limitation under s.154(6) and s.154(7), rendering it null and void; consequently, the Revenue was directed to refund the adjusted amounts with applicable interest within 8 weeks.</description>
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      <pubDate>Tue, 02 Dec 2025 00:00:00 +0530</pubDate>
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