Mandatory section 143(2) notice in reassessment is jurisdictional; absence of notice voids the proceedings and order.

A reassessment initiated after a return is filed in response to section 148 is jurisdictionally invalid if no notice under section 143(2) is issued. The text states that service of section 143(2) notice after the return is mandatory, and its omission creates a defect that section 292BB does not cure. On the stated record, the absence of notice was treated as admitted, so the reassessment proceedings and reassessment order were void ab initio and the objection on that ground succeeded.

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Issues: Whether reassessment proceedings and the reassessment order are invalid for want of issuance of notice under section 143(2) after the return was filed in response to notice under section 148.

Analysis: The return filed in response to the reassessment notice was not followed by issuance of notice under section 143(2). The defect was treated as admitted on the record. Notice under section 143(2) after filing of the return is mandatory, and its absence creates a jurisdictional defect. Such omission is not cured by section 292BB.

Conclusion: The reassessment proceedings were held void ab initio and the ground challenging the absence of notice under section 143(2) was allowed.

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