The ITAT held that an intimation u/s 143(1) is a summary assessment confined to arithmetical and apparent errors, and once scrutiny is initiated and completed u/s 143(3), the earlier 143(1) intimation merges into the regular assessment. In this case, an apparent mistake in the return was brought to CPC through an application u/s 154, and CPC transferred rectification rights to the JAO. The ITAT observed that the JAO, having completed assessment u/s 143(3) without making any adjustment or acting on the rectification application, effectively accepted the returned income. Consequently, sustaining the adjustment proposed earlier by CPC u/s 143(1) was held to be unjustified. The ITAT directed the JAO to rectify the mistake apparent on record and delete the demand raised u/s 143(1), allowing the assessee’s appeal.
ITAT: 143(1) intimation merges into 143(3) assessment; CPC adjustment invalid, JAO to rectify under 154
13. Case-Laws – AT : The ITAT held that an intimation u/s 143(1) is a summary assessment confined to arithmetical and apparent errors, and once scrutiny is initiated and completed u/s 143(3), the earlier 143(1) intimation merges into the regular assessment. In this case, an apparent mistake in the return was brought to CPC through an application u/s 154, and CPC transferred rectification rights to the JAO. The ITAT observed that the JAO, having completed assessment u/s 143(3) without making any adjustment or acting on the rectification application, effectively accepted the returned income. Consequently, sustaining the adjustment proposed earlier by CPC u/s 143(1) was held to be unjustified. The ITAT directed the JAO to rectify the mistake apparent on record and delete the demand raised u/s 143(1), allowing the assessee’s appeal.
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