In absence of issue of notice U/s. 143(2) assessment U/s. 143(3) r.w. section 147 was invalid and void ab initio

OFFHAND

In one’s longstanding firm conviction, the principal issue is centered on a very basic, rather elementary enactment; interpretation of which ought not to have posed any genuine difficulty, upfront. As such, by any sane thinking, the issue ought to have been, instead of being prolonged for years, regarded as clinched – fully finally settled long, long ago. A mere cursory look through the ITAT Order , particularly the host of case law cited and the long winding arguments of the Revenue, following beaten track, by reason of which the ITAT was obligated to discuss at such a great length , but ultimately to reach the only possible conclusion, rightly so in assessee’s favor, might have left anyone dazed and in utter bewilderment, over the rock bottom quality of the ‘legal system’, in its comprehensive sense, and the tax regime, in place !