No Section 143(2) Notice, No Jurisdiction: Reassessment Declared Null & Void

Urban Nirmal LLP Vs ITO (ITAT Kolkata) ITAT Kolkata held that reassessment framed u/s 147 r.w.s. 144/144B is invalid where mandatory notice u/s 143(2) was not issued. Assessee had originally filed return u/s 139(1) & in response to notice u/s 148, duly intimated AO to treat the original return as return filed pursuant to reopening. Despite this, AO failed to issue notice u/s 143(2) & proceeded to complete reassessment making addition of ₹1.24 crore towards cash credit. Tribunal admitted the additional legal ground challenging jurisdiction, holding that such a pure question of law can...