Section 144 Assessment Quashed for Failure to Issue Mandatory Section 143(2) Notice

Satya Enterprises Vs ITO (ITAT Raipur) The appeal was filed by the assessee against the order dated 23.04.2025 passed by the Commissioner of Income Tax (Appeals)/NFAC, Delhi for Assessment Year (AY) 2017–18. The assessment had originally been completed under section 144 of the Income-tax Act, 1961, vide order dated 24.11.2019. The assessee raised both legal grounds and grounds on merits. At the outset, the assessee pressed the legal issue, submitting that if the same was decided in its favour, the grounds on merits would become academic. The sole legal contention raised was that no notice un...