Audit-report disallowance under prima facie processing upheld, but rectification enhancing liability for the same claim was invalid

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....Audit report-based adjustment was permissible in prima facie processing where Clause 21(h) of Form 3CD disclosed a quantified section 14A disallowance not fully reflected in the return, because the amended processing provision allows such a limited adjustment; the jurisdictional challenge therefore failed for A.Y. 2022-23. Rectification that later enhanced liability on the same issue was invalid for A.Y. 2021-22, because section 154 requires notice, a reasonable opportunity of hearing, and proper consideration of the assessee's reply before increasing liability. On merits, the section 14A disallowance for both years was restricted to the amount already offered, since part of the reported figure had already been disallowed in computation and a larger disallowance could not be made without the required recorded dissatisfaction.....