A chargeback on a 3DS liability shift transaction can happen and is allowed if the dispute reason code is consumer related. As 3DS is only a full remedy against fraud, it does not apply to other reason codes, which you should defend.
In some instances, the bank is not able to verify the 3DS authentication (due to a technical error for example). There is no liability shift protection against fraud either in that case. For all information on the 3D Secure liability shift rules please read our documentation page: 3D Secure chargeback liability shift rules.
In the Adyen Customer Area, we display a tick mark on the payment page whenever a transaction has liability shift protection.