Section 263 Revision Invalid as Mandatory Section 143(2) Notice Was Never Issued

Star Tradecom Private Limited Vs ITO (ITAT Kolkata) The appeal before the ITAT Kolkata arose from an order of the National Faceless Appeal Centre for Assessment Year 2009-10. During the appellate proceedings, the assessee raised an additional legal ground challenging the validity of the reassessment proceedings. The assessee contended that the reassessment initiated through a notice under Section 148 and completed under Sections 147/143(3) was invalid because no statutory notice under Section 143(2) had been issued or served. It further argued that since the reassessment order itself was non e...