AO Cannot Reopen Assessment U/s. 147 Before 143(2) Period Expires: ITAT Mumbai

Urmish M. Udani Vs ACIT (ITAT Mumbai)

When time to issue 143(2) was still available, AO could not invoke 147 reopening held illegal entire assessment cancelled- ITAT Mumbai

Assessee, an individual & Managing Director of U.S. Roofs Ltd., filed his return of income belatedly on 14.06.2010 declaring ₹62.96 lakh. He subsequently filed a revised return on 16.06.2010 declaring ₹80.96 lakh. Since the return filed u/s 139(4) was a valid return, AO had time till 30.09.2011 to issue a notice u/s 143(2) to scrutinize the return.

However, instead of issuing a notice u/s

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