CPC had jurisdiction for audit-based adjustments, but double disallowance u/s 14A without hearing assessee was legally impermissible

Parle Biscuits Pvt. Ltd. Vs DCIT (ITAT Mumbai) Conclusion: Adjustment under section 143(1)(a)(iv) based on disallowance reported in Form 3CD was held to be within CPC’s jurisdiction. However, rectification under section 154 enhancing income without complying with section 154(3) was quashed. Since no satisfaction under section 14A(2) had been recorded and part of the expenditure had already been disallowed under section 37, disallowance under section 14A for both years was restricted to Rs. 1 lakh already offered by the assessee. Held: Assessee-company was engaged in the business of manuf...