Notice not become invalid for Mere non mention of ‘section 143(2)’ in it calling upon assessee to defend its case

Padinjarekara Agencies (P) Ltd. Vs CIT (Kerala High Court) Procedure under Section 143(2) is intended to ensure that an adverse order is passed against the assessee only after affording the assessee a proper opportunity. Therefore, the question to be considered is whether the assessee in this case had such an opportunity. It is in this context, the notices that were issued to the assessee assumes importance. Reading of the reasons recorded and communicated to the assessee, Annexure E notice posting the case, and Annexure I notice, show that the assessee was put on notice the inadmissibility of...