Rectification after regular assessment notice is impermissible when the return has already moved into section 143(2) proceedings.

An intimation under section 143(1)(a) could not be rectified under section 154 after the Income-tax Officer had issued notice under section 143(2), because the case had moved into regular assessment proceedings and the rectification route was no longer consistent with that process. The attempted correction of the initial intimation alongside the ongoing assessment was treated as an impermissible double rectification. The Calcutta High Court followed the view taken by other High Courts and held that such post-notice rectification was not justified, answering the issue in favour of the assessee.

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Issues: Whether an intimation issued under section 143(1)(a) of the Income-tax Act could be rectified under section 154 after issuance of notice under section 143(2).

Analysis: The Court held that once proceedings were taken forward by issuing notice under section 143(2), the rectification route under section 154 was not consistent with that course. The attempted rectification of the initial intimation, together with the regular assessment action, amounted to an impermissible double rectification, and the Court approved the view taken by other High Courts on the same point.

Conclusion: The question was answered in the affirmative and in favour of the assessee. Rectification under section 154 after issuance of notice under section 143(2) was not justified.

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