Section 10B export deduction dispute: whether Section 143(1) can make prima facie disallowance; deduction restored, refund ordered.

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....Whether deduction under Section 10B could be disallowed by way of prima facie adjustment in an intimation under Section 143(1) was examined. Since the allowability of the deduction was a debatable issue requiring scrutiny of factual and legal records, it fell outside the permissible scope of Section 143(1); the disallowance was therefore quashed and the deduction restored. Separately, the impugned rectification order was held time-barred under Sections 154(6) and 154(7), rendering it null and void; consequential refund of adjusted amounts with applicable interest was directed within eight weeks. - HC....