Reassessment u/s 148, in absence of notice u/s 143(2), unjustified

ITO Vs Mukesh Mahavirprasad Sen (ITAT Surat) Search was initiated against the assessee. However, notice was not issued u/s 143(2). AO reopened the matter and issued notice u/s 148. Held, reassessment of proceedings u/s 148, without issuance of notice u/s 143(2), is unsustainable in law Facts- AO had reason to believe that an income has escaped assessment in the hands of the assessee. Therefore, the case was reopened and notice u/s 148. In absence of any reply from the assessee, AO confirmed the bogus purchase. Being aggrieved, assessee carried the matter to CIT(A). CIT(A) quashed the reassessm...