Timely scrutiny notice is a jurisdictional requirement; a time-barred notice by the proper officer renders the assessment void.

A valid and timely notice under section 143(2) by the jurisdictionally correct Assessing Officer was treated as a jurisdictional prerequisite for scrutiny assessment. Because that notice was issued beyond the permissible time, the Tribunal held that the assessment was without jurisdiction and could not survive, so the assessment was quashed as void ab initio. Once the assessment failed on this threshold defect, the additions on merits were not examined and were left academic.

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Issues: Whether the assessment was without jurisdiction because the mandatory notice under section 143(2) was issued beyond the permissible time by the correct Assessing Officer, and whether the assessment was liable to be quashed on that ground.

Analysis: The return was filed under section 139(1), and the scrutiny proceedings were initiated through a notice under section 143(2). The decisive question was whether the notice issued by the jurisdictionally correct Assessing Officer was within time. The Tribunal accepted the assessee's objection that the notice issued by the correct Assessing Officer was time-barred and, following the settled principle that a valid and timely notice under section 143(2) is a jurisdictional requirement for scrutiny assessment, held that the assessment could not survive. Once the assessment itself was found to be without jurisdiction, the merits of the additions became academic and were not examined.

Conclusion: The assessment was held to be void ab initio and was quashed, with the additional legal ground allowed; the remaining grounds were left undecided as academic.

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