Issue of notice u/s 143(2) was mandatory even if return of income was filed beyond time limit provided u/s 142(1)

Haresh J Rathod Vs ITO (ITAT Rajkot) Conclusion: Once assessee had filed the Return of Income, in response to notice, u/s 142(1), (although it was late), then it was mandatory for AO, in order to acquire the jurisdiction, to make the assessment on the assessee, to issue the notice u/s 143(2). Held: In the instant case, the notice u/s 142(1) had been issued on 19/12/2017 requiring assessee to file return of income on or before 18/01/2018. However, assessee filed return of income beyond the time limit specified in notice u/s 142(1) of the Act on 03/06/2019. Therefore, the issue arose for conside...