Notice Not in Format, Assessment Falls Flat – ITAT Delhi Quashes 143(3) Order

Shilpi Sardana Vs DCIT (ITAT Delhi) ITAT Delhi quashed the assessment framed for AY 2021-22, holding that the notice issued u/s 143(2) was not in the CBDT-mandated format & hence invalid. Assessee had challenged the validity of assessment on multiple grounds, including limitation, non-existence of DIN & additions based only on WhatsApp chats. An additional legal ground was also sought: that the scrutiny notice dated 30.06.2022 was issued in violation of CBDT Instruction F.No.225/157/2017/ITA-II dated 23.06.2017, which prescribes mandatory formats for limited, complete & manual scru...