Protective addition in hands of agents without providing opportunity of being heard is invalid

Mohammad Rajiv Hakeem Vs ITO (ITAT Lucknow) Assessing officer has mentioned two sections framing the assessment i.e., 144/147. For proceeding ahead to frame an assessment under section 147, the assessing officer is bound to issue notice under section 148 of the Act. As per the available record, no such notice was issued and this fact is accepted by the Revenue also. We further observe that as per the provisions of section 163(2) of the Act, which deals with the procedure to examine as to who may be regarded as an agent in relation to a non-resident and the provision specifically mentions that ...