Processing rectification application u/s 154 without giving reasonable opportunity is unsustainable

Nakodar Primary Cooperative Vs ITO (ITAT Amritsar) ITAT Amritsar held that a reasonable opportunity should be given to the assessee before making addition u/s 40A(7) of the Income Tax Act before processing rectification application u/s 154. Facts- During processing the return u/s 143(1) the provision for payment of gratuity, u/s 40A(7) of the Act was rejected amount to 3,22,425/-. The assessee filed a rectification petition before the CPC u/s 154. But the CPC has rejected the rectification petition u/s 154 of the Act. Aggrieved assessee filed an appeal before the ld. CIT(A). The ld. CIT(A) uph...