On failing to file return under Section 139 (1), which assessment made first section 144 or section 147, as both notices can be issued after failing to file return under Section 139(1)
Section 144- best judgment assessment if any person fails to file return of income u/s 139-1 and has not made belated return u/s 139-4 or revised return u/s 139-5
section 147- income escape assessment if AO has reasons to believe that any income chargeable for tax of any assessment yr has escaped assessment then he has power to assess such income
AO will issue notice u/s 142-1, calling for filing return to br filed. If return if filed and if taxes paid if payable then no issues orels assessment is done u/s 147 by issuing notice u/s 148. If stil no response then actions taken u/s 144.