Jurisdictional notice under section 143(2) is essential for reassessment; absence of proof rendered the assessment unsustainable.

A notice under section 143(2) was treated as a jurisdictional prerequisite for completing the reassessment under sections 143(3) read with 147. As no such notice, or supporting record showing its issue, was produced despite a prior direction, the assessment was held unsustainable and was quashed. The remaining grounds became academic once the reassessment failed for want of valid notice.

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Issues: Whether the reassessment framed under section 143(3) read with section 147 of the Income-tax Act, 1961 was valid in the absence of a notice under section 143(2).

Analysis: The notice under section 143(2) was treated as a jurisdictional requirement for completing the assessment. As no such notice or supporting record was produced despite a prior direction, the assessment was held to be unsustainable. The remaining grounds were rendered academic.

Conclusion: The assessment was quashed for want of a valid notice under section 143(2), and the assessee succeeded on the sole substantive issue.

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