Reassessment notice U/s. 147/148 is invalid when period to issue notice U/s. 143(2) has not expired

Smt. Suman Vs. ITO (Bombay High Court) Where the period of issuing notice under section 143(2) of the Act has not expired, then reassessment notice under section 147/148 of the Act was invalid. An Assessing officer cannot initiate reassessment proceedings, where intimation under section 143(1) has been issued and the Revenue failed to take steps to issue notice under section 143(2) and complete assessment under section 143(3) of the Act. The aforesaid contention was negatived in the above referred para on the ground that in the context of the facts before it, the time to issue notice under sec...