Section 143(1) order is not an Assessment for Section 147

Ernst And Young U.S. LLP Vs ACIT (Delhi High Court) Supreme Court and this Court have repeatedly held that when the original proceeding has been completed under Section 143(1), there is no need for fresh tangible material for reopening the assessment and the doctrine of change of opinion does not arise since under Section 143(1) an intimation is issued and no opinion is formed by way of the said order. The Supreme Court in Assistant Commissioner of Income Tax Vs. Rajesh Jhaveri Stock Brokers Private Limited, (2008) 14 SCC 208, has held that there is a distinction between ‘intimation’ and â...