Section 143(3)/147 Assessment invalid Without Valid Section 143(2) Notice

Girishbhai Nanjibhai Solanki Vs ITO (ITAT Rajkot) In the case of Girishbhai Nanjibhai Solanki Vs. ITO, the Income Tax Appellate Tribunal (ITAT) Rajkot examined the validity of assessments made under Sections 143(3 read with Section 147 of the Income Tax Act, focusing specifically on the procedural requirements regarding the issuance of notice under Section 143(2). The assessments in question were contested on the grounds that the notice was issued after the statutory deadline, which is critical for establishing the Assessing Officer’s (AO) jurisdiction to assess the income of the taxpay...