Reassessment order was quashed in absence of a valid section 143(2) notice

Vinod Mongia Vs ITO (ITAT Delhi) Conclusion: Reassessment order passed under Section 147/143(3) was quashed on the ground that no notice under Section 143(2) was issued after the assessee filed the return in response to notice under Section 148, rendering the assessment void ab initio. Even if the tax department had strong information suggesting tax evasion, a failure to follow the mandatory procedural steps required by the Act will invalidate the entire assessment. Held: AO initiated reassessment proceedings against the assessee by issuing a notice under Section 148, based on information abou...