Invalid 143(2) Notice Makes Assessment Non-Est: ITAT Quashes Entire Assessment

Ankur Dealcom P. Limited Vs ITO (ITAT Kolkata)

Kolkata ITAT ‘ allowed the appeal of Ankur Dealcom P. Limited for AY 2021-22 holding that the assessment framed u/s 143(3) was void ab initio as the notice u/s 143(2) was not issued in the mandatory revised formats prescribed by CBDT Instruction F.No.225/157/2017/ITA-II dated 23-06-2017. The Tribunal noted that the coordinate bench, while dealing with revisionary proceedings u/s 263 in Assessee’s own case, had already categorically held that the very notice u/s 143(2) culminating in the impugned as

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