Premature or Time-Barred Section 143(2) Notices Invalidate Assessment: ITAT Mumbai

Urmish M. Udani Vs ACIT (ITAT Mumbai) No valid notice u/s 143(2); one notice was premature (before return) & the other was time-barred- Entire 147/143(3) assessment held void ab initio – ITAT Mumbai quashes reassessment A survey u/s 133A was conducted in the case of U.S. Roofs Ltd. & U.S. Realty Ltd. (group concerns of the assessee, who was the Managing Director). AO issued a notice u/s 148 on 24.11.2010, & simultaneously issued notice u/s 142(1) & 143(2) on 02.02.2011. However, Assessee filed his return of income only on 03.03.2011. Tribunal noted a crucial jurisdictiona...