Dismissing the petition the Court held that, when the notice u/s 143(2) is issued and assessment is pending, right to claim refund could not accrue. Decision of the AO using his discretion under section 143(1D), did not process these returns considering fact that substantial demand would be raised on completion of scrutiny assessment of these years is held to be justified. Instruction No. 2/2015, dt. 13-1-2015. (AY. 2014-15 to 2017-18)
Vodafone Mobile Services Ltd. v. ACIT (2019) 260 Taxman 417 /173 DTR 34 / 306 CTR 12/( 2020) 421 ITR 193 (Delhi)(HC)
S. 143(1D) : Assessment–Notice u/s 143(2) is issued for, processing of return -Processing the return for issue of refund is not required -Writ to process the return and issue of refund is dismissed. [S. 143(1),143(2), 143(3), 241 , 241A ]