Faceless reassessment remains valid where section 143(2) notice is properly issued, while ex parte additions need fresh factual verification.

Valid issuance of notice under section 143(2) by the Jurisdictional Assessing Officer satisfies the jurisdictional requirement in faceless reassessment, and completion of assessment by the faceless unit under section 144B does not by itself vitiate the proceedings. The challenge to reassessment on that ground failed. Additions made ex parte on short-term capital gain, estimated business and professional income, and rent receipts required fresh factual verification because the record did not adequately examine purchase documents, holding period, books, reconciliation, or the nature of receipts. Those additions were set aside and restored for fresh adjudication after giving the assessee reasonable opportunity.

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Issues: (i) Whether reassessment completed under section 147 read with section 144B was invalid because notice under section 143(2) was issued by the Jurisdictional Assessing Officer and not by the Assessment Unit. (ii) Whether the additions on merits, including short-term capital gain, estimated business income on contract and professional receipts, and addition of rent receipts, could be sustained without fresh factual verification.

Issue (i): Whether reassessment completed under section 147 read with section 144B was invalid because notice under section 143(2) was issued by the Jurisdictional Assessing Officer and not by the Assessment Unit.

Analysis: The mandatory requirement is the issuance of notice under section 143(2) by a competent Assessing Officer. The statutory scheme does not require that the same officer who issues the notice must also complete the assessment. Under the faceless regime, section 144B governs the manner of completing assessment and does not extinguish the jurisdiction otherwise vested in the Jurisdictional Assessing Officer under section 120. The record showed that notice under section 143(2) had in fact been issued by the Jurisdictional Assessing Officer. Section 292BB did not arise where the notice itself stood issued. The authorities relied upon by the parties were harmonised, and the bifurcation between issuance of notice and completion of assessment was held not to vitiate the proceedings.

Conclusion: The challenge to the validity of the reassessment on this ground was rejected and the assessment was not held invalid.

Issue (ii): Whether the additions on merits, including short-term capital gain, estimated business income on contract and professional receipts, and addition of rent receipts, could be sustained without fresh factual verification.

Analysis: The additions were made ex parte and largely on the basis of non-compliance and data from information sources. The short-term capital gain was computed by adopting nil cost without verifying purchase documents, period of holding, nature of asset, or computation under the capital gains provisions. The estimations on contract and professional receipts were made on ad hoc percentages without proper examination of books or reconciliation, and the rent receipts required correlation with the accounts and the nature of the income. At the same time, the assessee had not furnished adequate material before the lower authorities. In these circumstances, the factual matrix required fresh examination to ensure proper computation in accordance with law.

Conclusion: The additions on merits were set aside and restored to the Assessing Officer for fresh adjudication after giving reasonable opportunity to the assessee.

Final Conclusion: The legal objection to the reassessment failed, but the additions on merits were remitted for fresh consideration, resulting in partial relief to the assessee for statistical purposes.

Ratio Decidendi: In a faceless reassessment, valid issuance of notice under section 143(2) by a competent Jurisdictional Assessing Officer satisfies the jurisdictional requirement, and completion of assessment by the faceless unit under section 144B does not by itself invalidate the proceedings; where additions are made ex parte without adequate verification, they may be restored for fresh adjudication.

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