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ITAT Mumbai: CPC Adjustment Merges with Section 143(3) Scrutiny Assessment

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Summary

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  • ITAT Mumbai has allowed the appeal of National Stock Exchange of India Limited, overturning a CPC adjustment of Rs. 35,23,99,063 related to "Abandoned Project Expenses."
  • The Tribunal found that the CPC failed to consider the assessee's objections and rectification application regarding the adjustment under Section 143(1).
  • It ruled that the CPC action was unsustainable as the scrutiny assessment under Section 143(3) rendered the earlier adjustment moot.
  • This decision reinforces the doctrine of merger in tax assessments, potentially impacting future CPC adjustments and scrutiny processes.

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