https://www.taxtmi.com/caselaws?id=22727 HC upheld the validity of notices issued under s.143(2) and rejected the challenge to s.143(1)(a)(i) as ultra vires or violative of natural justice. It held that intimation under s.143(1)(a)(i), though deemed a notice of demand under s.156 by statutory fiction, is "without prejudice" to the AO's power to proceed under s.143(2) and complete a scrutiny assessment under s.143(3), which remains appealable under s.246(1)(a). The fiction is limited to recovery purposes and does not bar regular assessment or require recourse only to s.147. Adjustments under s.143(1)(a) are confined to prima facie, non-debatable errors. The writ petition was dismissed. en-us Fri, 28 Dec 1990 00:00:00 +0530 Wed, 10 Dec 2025 15:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=22727 HC upheld the validity of notices issued under s.143(2) and rejected the challenge to s.143(1)(a)(i) as ultra vires or violative of natural justice. It held that intimation under s.143(1)(a)(i), though deemed a notice of demand under s.156 by statutory fiction, is "without prejudice" to the AO's power to proceed under s.143(2) and complete a scrutiny assessment under s.143(3), which remains appealable under s.246(1)(a). The fiction is limited to recovery purposes and does not bar regular assessment or require recourse only to s.147. Adjustments under s.143(1)(a) are confined to prima facie, non-debatable errors. The writ petition was dismissed. Case-Laws Income Tax Fri, 28 Dec 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=22727