Income-tax assessment notices under s. 143(2) vs s. 143(1)(a) intimation-summary intimation barred after regular assessment begins.

Once the AO issues notice for regular assessment under s. 143(2) of the Income-tax Act, the Revenue cannot thereafter issue an intimation under s. 143(1)(a). The SC held that s. 143(1)(a) provides a summary mechanism for quick tax collection/refunds, and the statutory phrase "without prejudice to" s. 143(2) permits a regular assessment to follow a summary intimation, but not vice versa. Since commencement of proceedings under s. 143(2) renders a summary proceeding unnecessary and impermissible, the HC's view was affirmed and the appeals were dismissed.

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The Supreme Court dismissed appeals against Gujarat High Court orders stating no substantial question of law arose regarding the Revenue issuing intimation under section 143(1)(a) after notice for regular assessment under section 143(2) of the Income-tax Act, 1961. The High Court's decision was upheld as it aligned with the legislative intent and the appeals were dismissed.

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