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Mandatory notice under section 143(2) was treated as a jurisdictional precondition for completing reassessment under section 147 read with section 143(3); because the records did not show issuance of such notice before the draft assessment stage, the reassessment was held invalid for want of jurisdiction. The Tribunal further held that a purported draft order under section 144C ceases to be a mere proposal where it already directs tax demand, interest, credit adjustment and penalty initiation; in substance it is a final assessment order passed contrary to the statutory scheme. On that basis, the draft orders, final assessments and consequential proceedings were quashed, and the remaining issues were left academic.
Mandatory notice under section 143(2) was treated as a jurisdictional precondition for completing reassessment under section 147 read with section 143(3); because the records did not show issuance of such notice before the draft assessment stage, the reassessment was held invalid for want of jurisdiction. The Tribunal further held that a purported draft order under section 144C ceases to be a mere proposal where it already directs tax demand, interest, credit adjustment and penalty initiation; in substance it is a final assessment order passed contrary to the statutory scheme. On that basis, the draft orders, final assessments and consequential proceedings were quashed, and the remaining issues were left academic.
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