Format Matters: ITAT Says Invalid 143(2) Notice Vitiates Whole Proceedings

Hindcon Chemicals Limited Vs DCIT (TAT Kolkata) Assessee challenged the reassessment completed u/s 143(3)/147 on the ground that the notice issued u/s 143(2) dated 20.07.2017 was invalid since it did not specify whether the case was selected for limited scrutiny, complete scrutiny, or compulsory manual scrutiny, contrary to mandatory CBDT Instruction No. F.225/157/2017/ITA-II dated 23.06.2017 prescribing specific formats for such notices. Assessee argued that non-compliance with this instruction renders the notice invalid, thereby vitiating the entire assessment. AO contended that the notice w...