Deeming fiction U/s. 292BB not applicable on failure to issue notice U/s. 143(2) within specified period

Tiny Girl Clothing Company (P) Ltd. Vs. DCIT (ITAT Mumbai)

 In the case on hand we see that the notice under section 143(2) itself is dated 19-1-2015 which is beyond the date prescribed for issue of notice i.e. 30-9-2012. In such circumstances the assessing officer could not have issued any notice prior to 30-9-2012. Therefore, admittedly in this case as the notice under section 143(2) was issued beyond 30-9-2012 and in view of the decision of the Hon’ble Allahabad High Court the assessing officer could not have assumed jurisdic

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