Illegal Section 143(2) Notice Vitiates Search-Based Assessment

KJL Developers (P) Ltd. Vs DCIT (ITAT Delhi) 153C Assessment Quashed: Invalid 143(2) Notice and Defective Satisfaction Note Vitiate Entire Proceedings The Delhi Bench “C” of the ITAT, in KJL Developers (P.) Ltd. v. DCIT (AY 2014-15), quashed the assessment framed under section 153C read with section 143(3), holding that the very assumption of jurisdiction was invalid. The case arose from a search conducted in the Dalal Group in September 2017, based on which proceedings under section 153C were initiated against the assessee on the strength of loose sheets allegedly evidencing cash payments...