It may be noted that Assessee isn’t precluded from filing revised return though intimation under Sec. 143(1) issued by the Dept. The same view is expressed in

ACIT v. Padma Logistics & Khanij (P.) Ltd. – [2020] 117 taxmann.com 210 (Kolkata – Trib.)

The Kolkata Tribunal held that the right to file a revised return of income does not lapse with the issuance of intimation under section 143(1) of the Income-tax Act, 1961.

Intimation issued under section 143(1) cannot be said to be a ‘completion of assessment’ and more so when the assessment has subsequently been completed under section 143(3) of the Act.

The Tribunal has placed reliance on the judgment of the Hon’ble Supreme Court in the case CIT v Rajesh Jhaveri Stock Brokers Pvt. Ltd. [2007] 161 Taxman 316 (SC) wherein it was held that the expressions ‘intimation’ and ‘assessment order’ have been used at different places.

The contextual difference between the two expressions has to be understood in the context the expressions are used.

The assessment is used as meaning sometimes ‘the computation of income’, sometimes ‘the determination of the amount of tax payable’ and sometimes ‘the whole procedure laid down in the Act for imposing liability upon the taxpayer’.

In the scheme of things, as noted above, the intimation under section 143(1)(a) cannot be treated to be an order of assessment.