Manual Section 143(2) Notices Without DIN Invalid: ITAT Delhi

ITO Vs Lalita Agarwal (ITAT Delhi) Manual Section 143(2) Notices Without DIN Invalid: ITAT Quashes Reassessments as Void Ab Initio for Five Years The Delhi ITAT allowed the assessee’s appeals and quashed reassessment orders for AYs 2012-13 to 2016-17, holding that the assumption of jurisdiction under Section 147 was invalid due to absence of a valid notice under Section 143(2). Though the Revenue produced manually issued notices dated 07.11.2019, the Tribunal found that these notices were neither reflected in the ITBA portal timeline nor issued in conformity with CBDT Circular No.19/2019 man...