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The High Court held that the assessment order u/ss 144 and 144B cannot be completed without issuing a notice u/s 143(2). Reliance on the petitioner's PAN database or an alternate email address cannot substitute for statutory compliance. Procedural irregularities in issuing and serving notices undermine the jurisdiction and legality of the entire assessment process. Consequently, the assessment order passed by the respondent authorities without issuing a proper notice u/s 143(2) was declared bad in law and set aside. The High Court quashed the impugned assessment order, demand notice, and penalty notices, directing the respondent authorities to issue fresh notices, if deemed necessary, strictly adhering to statutory provisions and ensuring proper service to the petitioner.
The High Court held that the assessment order u/ss 144 and 144B cannot be completed without issuing a notice u/s 143(2). Reliance on the petitioner's PAN database or an alternate email address cannot substitute for statutory compliance. Procedural irregularities in issuing and serving notices undermine the jurisdiction and legality of the entire assessment process. Consequently, the assessment order passed by the respondent authorities without issuing a proper notice u/s 143(2) was declared bad in law and set aside. The High Court quashed the impugned assessment order, demand notice, and penalty notices, directing the respondent authorities to issue fresh notices, if deemed necessary, strictly adhering to statutory provisions and ensuring proper service to the petitioner.
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