No 143(1) Show-Cause Issued: ITAT Quashes ₹5.73 Cr Demand for TDS Mismatch

Faurecia Emissions Control Technologies India Pvt. Ltd. Vs ACIT (ITAT Chennai)

143(1) Adjustment Invalid: 139(9) Notice Cannot Replace Mandatory Show-Cause- 143(1) Adjustment for TDS Credit Invalid Without Prior Intimation; Entire Demand Deleted

Chennai ITAT examined legality of an adjustment u/s 143(1)(a) whereby CPC denied TDS credit of Rs.5,05,37,430 & raised a consequential demand of Rs.5,73,47,460. Revenue justified denial on the basis of mismatch between receipts disclosed in ROI (Rs.930 crore) & receipts in Form 26AS (Rs.1567 crore), applying

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