Jurisdiction Defect: ITAT Voids Entire Assessment Where 143(2) Notice Ignored CBDT Mandatory Instructions

Sunil Singh Vs ITO (ITAT Kolkata)

Notice Missing ‘Limited or Complete Scrutiny’ Label? Entire Assessment Becomes Void Invalid 143(2) Notice = No  

This appeal deals with a crucial jurisdictional defect that strikes at the very root of the assessment – the validity of the notice issued under Section 143(2).

 Assessee’s appeal reached the ITAT with a delay of 288 days, but the delay was supported by an affidavit explaining genuine reasons, &  even the Department did not object. Tribunal,

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