Mandatory notice under section 143(2) was treated as a...

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.