Reopening of assessment u/s 147 - For section 292BB to apply,...

Reopening of assessment u/s 147 - For section 292BB to apply, the notice must have emanated from the Department. It is only the infirmities in the manner of service of notice that section seeks to cure. The section is not intended to cure complete absence of notice itself. Since the facts on record are clear that no notice under section 143(2) of the Act was however issued by Department, the finding rendered by the High Court and the Tribunal and the conclusion arrived at were correct. - AT