ITAT Quashes Reassessment for Missing Sec 143(2) Notice even after Section 148 Return

Nisha Kapistalamchetlur Vs ITO (ITAT Hyderabad) The Hyderabad ITAT quashed the reassessment for AY 2013-14 & 2014-15 on a fundamental jurisdictional defect. The assessee had filed a return (though belatedly) in response to notice issued under Section 148, but the AO treated the return as non-est and proceeded to complete assessment without issuing notice under Section 143(2). The Tribunal held that a return filed in response to Section 148-even if delayed-remains a valid return in the eyes of law if filed during the pendency of proceedings. Once such return is filed, the AO is mandatorily...