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The notice u/s 143(2) of the Income Tax Act was issued on 15.10.2013, beyond the prescribed time limit of six months from the end of the assessment year, i.e., 30.9.2013. The assessee failed to challenge the validity of the notice before the Assessing Officer and Commissioner of Income Tax (Appeals). The Income Tax Appellate Tribunal held that the initiation of proceedings and jurisdiction invoked by the Assessing Officer suffered from infirmity as the notice u/s 143(2) was issued beyond the statutory time limit. Consequently, the Tribunal ruled the impugned assessment order as invalid, rendering the issues raised on merits academic and not requiring adjudication.
The notice u/s 143(2) of the Income Tax Act was issued on 15.10.2013, beyond the prescribed time limit of six months from the end of the assessment year, i.e., 30.9.2013. The assessee failed to challenge the validity of the notice before the Assessing Officer and Commissioner of Income Tax (Appeals). The Income Tax Appellate Tribunal held that the initiation of proceedings and jurisdiction invoked by the Assessing Officer suffered from infirmity as the notice u/s 143(2) was issued beyond the statutory time limit. Consequently, the Tribunal ruled the impugned assessment order as invalid, rendering the issues raised on merits academic and not requiring adjudication.
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