Northern Arc Investment Managers (P.) Ltd. v. DDIT (2025) 171 taxmann.com 305 / 472 ITR 154 (Mad)(HC)

S. 143(1) : Assessment-Intimation-Prima facie adjustment-Corrections to returns must be intimated to the assssee-Reply of assessee must be considered-Application for rectification u/s 154 not considered-Scrutiny proceedings initiated, AO directed to consider the assessee’s reply and thereafter initiate scrutiny proceedings under Faceless Assessment Scheme. [S. 154, Art. 226]

For the AY: 2022-23, the assessee-company filed its return of income.  The return of income has been processed and an intimation u/s 143(1) with some discrepancies has been served.  The AO directed the assessee to file its reply during the period of 30 days.  Though the reply filed by the assessee, the AO had not considered the same and initiated scrutiny proceedings.

On Writ, the Hon’ble High Court found that the AO has not considered the reply filed with explanation for the adjustments made in the intimation u/s 143(1) of the Act.  The Hon’ble Court held that the AO is directed to consider the reply filed by the assessee and accept the ITR accordingly, and thereafter, the Faceless Assessment Officer shall proceed further by providing the opportunity of hearing before passing an order in the scrutiny assessment.  (AY. 2022-23) 

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