Regular assessment under section 143(2) bars parallel intimation under section 143(1)(a) in income-tax processing.

After notice for regular assessment is issued under section 143(2) of the Income-tax Act, the Revenue cannot simultaneously issue an intimation under section 143(1)(a). The statutory scheme treats section 143(1)(a) as a summary procedure for quick collection and refunds, expressly without prejudice to section 143(2), but not the other way around. Once regular assessment proceedings have commenced under section 143(2), parallel summary processing under section 143(1)(a) is not contemplated. Rectification under section 154 remains available for serious objections to the assessment.

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Issues: Whether, after notice for regular assessment has been issued under section 143(2) of the Income-tax Act, 1961, the Revenue can still issue intimation under section 143(1)(a) of the same Act.

Analysis: Section 143(1)(a) provides a summary procedure for quick collection of tax and quick refunds, and the intimation issued under that provision is expressly without prejudice to section 143(2). The statutory scheme shows that where the summary procedure under section 143(1)(a) is adopted, the Revenue may still proceed to regular assessment under section 143(2). The converse is not contemplated. Once regular assessment proceedings have commenced under section 143(2), there is no occasion for a parallel summary proceeding under section 143(1)(a). Section 154 remains available for rectification of serious objections to the assessment.

Conclusion: The Revenue cannot issue intimation under section 143(1)(a) after regular assessment proceedings have commenced under section 143(2); the issue is answered against the Revenue and in favour of the assessee.

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