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Reassessment completed under section 147 read with section 143(3) without issuance of mandatory notice under section 143(2) was held void by the ITAT. The record, including RTI material, did not show issuance of notice, and section 292BB was held to cure only defects in service, not the complete absence of notice. As the reassessment was a nullity, the consequential revision under section 263 could not survive. The Tribunal also held that the invalidity of the underlying reassessment could be raised in collateral or consequential proceedings even without a separate challenge to the reassessment order.
Reassessment completed under section 147 read with section 143(3) without issuance of mandatory notice under section 143(2) was held void by the ITAT. The record, including RTI material, did not show issuance of notice, and section 292BB was held to cure only defects in service, not the complete absence of notice. As the reassessment was a nullity, the consequential revision under section 263 could not survive. The Tribunal also held that the invalidity of the underlying reassessment could be raised in collateral or consequential proceedings even without a separate challenge to the reassessment order.
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