2002 (8) TMI 407
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....us challenging the order of the CIT(A) dated 21st February, 1997, hereinafter called the impugned order on the grounds reproduced below :- "1. That having regard to the facts and circumstances of the case, ld. CIT(A) has erred in law and on facts in confirming the action of ld. AC in rectifying the intimation under section 143(1)(a) by resorting to the provision of section 154 and that too after ....
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.... ground that the assessee had credited a sum of Rs. 1,01,273 to the profit and loss account, but had not offered it to tax as the income of the assessee. Though the appellant as per record had credited the said sum of Rs. 1,01,273 to the profit and loss account, but claimed that the sum was not taxable. This belief of the appellant persuaded him not to bring the amount of Rs. 1,01,273 to the incom....
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....ld. AR submitted that once the return was processed under section 143(1)(a) of the Income-tax Act, the provisions of section 154 could not be invoked. It was further submitted by the ld. AR that no addition ought to have been made once the intimation under section 143(1)(a) was sent to the assessee. 7. To the arguments raised by the ld. AR, ld. DR relied upon the order of the authorities below. ....