Reassessment without notice u/s 143(2) was bad in law & cannot be revised u/s 263

M/s. Supersonic Technologies Pvt. Ltd. Vs PCIT (ITAT Delhi)

Conclusion: Since no notice under section 143(2) had been issued for completion of the re-assessment proceedings, therefore, the re-assessment order itself was bad in law and the same could not be revised under section 263.

Held:

A.O reopened assessment but did not mention if he had issued any notice under section 143(2) upon assessee before completion of assessment. This issue was raised before CIT in the proceedings

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