#CPC adjustment

The ITAT Delhi has ruled that the CPC cannot unilaterally treat foreign contributions disclosed under FCRA as undisclosed income under Section 143(1), especially when the assessee has consistently reported them over multiple years. This sets a critical precedent for NGOs and non-profits, affirming that mechanical adjustments without verification violate procedural fairness and the principle of tax consistency.

The ITAT Kolkata has ruled that the Centralized Processing Centre cannot make tax adjustments under Section 143(1) without first issuing a show-cause notice to the assessee, violating the foundational principle of natural justice. This sets a critical precedent for all taxpayers whose returns are processed automatically, ensuring procedural fairness in AI-driven tax assessments.