Notice u/s 143(2) issued prior to filing of return in response to notice u/s 147 is invalid, even if return is filed late

CA Prarthana Jalan Hon’ble Bangalore ITAT has in the case of Shri G.N.Mohan Raju,v/s ITO in ITA No.242 & 243(Bang) 2013 has held that notice u/s 143(2) issued prior to filing of return in response to notice u/s 147 is invalid, even if return is filed late. AO could not treat a return filed prior to issue of notice u/s 148 of the Act as a return filed by the assessee, pursuant to such notice unless and until assessee had given a direction or request on these lines. Operation of Section 143(2) of the Act is with reference to a return filed by the assessee. The assessments were complete...