Participation Does Not Validate Notice Issued by Wrong Officer

Harish Chand Gupta Vs ITO  (ITAT Delhi) Notice by Wrong AO = Fatal: 143(2) by Non-Jurisdictional AO Vitiates Entire Assessment: Participation Doesn’t Cure Jurisdictional Defect Delhi ITAT ‘C’ Bench in Harish Chand Gupta vs ITO, Ward-34(1), Delhi (ITA No.671/Del/2025, AY 2017-18, order dated 23-12-2025) quashed the entire assessment holding that notice u/s 143(2) issued by a non-jurisdictional AO is a nullity, and the defect is not curable u/s 292BB. Assessee’s return was processed u/s 143(1) and the case was selected for scrutiny on multiple parameters including demonetisation cash de...