Notice U/s. 148 invalid if AO not issued notice U/s. 143(2)

Pr. CIT Vs. Paramount Biotech Industries Ltd. (Delhi High Court)

The proposal to reopen an assessment under section 147 of the Act is to be based on reasons to be recorded by the assessing officer. Such reasons have to be communicated to the assessee. However, merely because the assessee participates in the proceedings pursuant to such notice under section 148 of the Act, it does not obviate the mandatory requirement of the assessing officer having to issue to the assessee a notice under section 143(2) of the

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