No 143(2) Needed in Search Cases; NP Rate Recast & Loan Issue Partly Restored

Sunil Gupta Vs ACIT (ITAT Delhi) In this search-assessment appeal, Assessee contended that assessment u/s 153A r.w.s 143(3) was invalid since no notice u/s 143(2) was issued after filing return in response to notice u/s 153A. Tribunal, applying the Delhi High Court ruling in Ashok Chaddha, held that in search cases a separate notice u/s 143(2) is not mandatory once notice u/s 153A has already been issued, & questionnaires issued during proceedings adequately satisfy the requirement of opportunity. This ground was therefore dismissed. On the addition relating to differential sales, Assessee...