https://www.taxtmi.com/caselaws?id=410194 HC held that an intimation issued u/s 143(1) is not an "assessment order" and, therefore, reopening u/s 147/148 in such circumstances amounts to a first assessment, not a reassessment. Consequently, the AO was required to frame the assessment de novo and consider all claims of the assessee, unhindered by the limitations applicable to reassessment proceedings. The HC further observed that even if a 143(1) intimation were treated as an assessment, the original proceeding stands effaced upon reopening, again necessitating a fresh, comprehensive consideration of the assessee's claims. en-us Tue, 06 Jul 2021 00:00:00 +0530 Mon, 01 Dec 2025 17:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=410194 HC held that an intimation issued u/s 143(1) is not an "assessment order" and, therefore, reopening u/s 147/148 in such circumstances amounts to a first assessment, not a reassessment. Consequently, the AO was required to frame the assessment de novo and consider all claims of the assessee, unhindered by the limitations applicable to reassessment proceedings. The HC further observed that even if a 143(1) intimation were treated as an assessment, the original proceeding stands effaced upon reopening, again necessitating a fresh, comprehensive consideration of the assessee's claims. Case-Laws Income Tax Tue, 06 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=410194