Mandatory reassessment notice requirement invalidates assessment where jurisdictional notice is defective and timely objection is raised.

Compliance with the statutory notice requirement under the Income-tax Act was treated as mandatory in reassessment proceedings, and non-issuance or invalid service of the jurisdictional notice was not a mere procedural irregularity. The Court noted that the reassessment framework under Sections 147, 148 and the notice requirement under Section 143(2), read with the jurisdictional scheme under Sections 2(7A) and 120 and the faceless assessment provisions under Section 144B, must be followed validly. Section 292BB did not cure the defect where the assessee had raised a timely objection. The Tribunal was therefore right in holding the reassessment order invalid, and the challenge failed.

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Issues: Whether the Tribunal was right in holding that the reassessment order was bad in law for want of valid jurisdiction and compliance with the notice requirements under the Income-tax Act, 1961.

Analysis: The appeal turned on the validity of the notice and assessment process in a reassessment matter. The Court noted that the issue was already covered by earlier decisions holding that the notice requirement under Section 143(2) is mandatory and that non-issuance of such notice is not a mere procedural irregularity. It also noted the statutory definition of assessing officer under Section 2(7A), the jurisdictional scheme under Section 120, the reassessment provisions under Sections 147 and 148, the faceless assessment framework under Section 144B, and the limited operation of Section 292BB where the assessee has raised a timely objection. In light of the earlier binding decisions relied upon, the Court found that the Tribunal had correctly treated the assessment as invalid.

Conclusion: The challenge failed and the Tribunal's view was upheld; the issue was answered against the Revenue.

Final Conclusion: The reassessment was not sustained, and the appeal was dismissed with the substantial question of law decided against the Revenue.

Ratio Decidendi: Compliance with the statutory notice requirement is mandatory, and where the jurisdictional notice is not validly issued or served, the defect is not cured by Section 292BB if a timely objection has been raised.

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