The Appellate Tribunal held that the issuance of a valid notice...

The Appellate Tribunal held that the issuance of a valid notice u/s 143(2) is a prerequisite for framing a valid assessment, in line with the Supreme Court's judgments in Hotel Blue Moon and Laxman Das Khandelwal. The Tribunal found that the Assessing Officer had failed to issue a valid notice u/s 143(2) before framing the assessment u/s 147. The Tribunal was unable to accept the revenue's contention to cover the issue u/s 292BB. Consequently, the Tribunal quashed the assessment framed by the Assessing Officer u/s 147 due to the lack of a valid assumption of jurisdiction arising from the non-issuance of notice u/s 143(2), deciding in favor of the assessee.