ITAT Kolkata Quashes Assessment for Invalid 143(2) Notice Issued in Wrong Format

Gautam Kumar Sadhu Vs ACIT (ITAT Kolkata) This case goes to the root of jurisdiction & demonstrates how an invalid or improper notice u/s 143(2) renders the entire assessment void. Assessee’s appeal reached Tribunal with a delay of 352 days, which he explained by stating that CIT(A) never issued notices to his registered e-mail, & he only discovered the order after inquiring with AO. Tribunal found the cause bona fide condoned the delay in the interest of justice. Assessee then challenged the assessment on two strong legal grounds: No valid notice under Section 143(2) The only 143(2)...