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ITAT dismissed revenue's appeal in reassessment proceedings u/s 147. Despite AO treating assessee's return as non-est due to lack of e-verification, AO computed assessed income from returned income, indicating cognizance of the return. Assessee rectified e-verification defect immediately upon notification. AO failed to issue mandatory notice u/s 143(2) and furnish reasons for reopening assessment, constituting jurisdictional defects not curable u/s 292BB. ITAT held these procedural failures fatal to reassessment proceedings, relying on Hotel Blue Moon and CIT vs Trend Electronics precedents establishing that absence of s.143(2) notice invalidates assumption of jurisdiction and non-furnishing of reopening reasons renders reassessment proceedings void. Reassessment proceedings quashed.
ITAT dismissed revenue's appeal in reassessment proceedings u/s 147. Despite AO treating assessee's return as non-est due to lack of e-verification, AO computed assessed income from returned income, indicating cognizance of the return. Assessee rectified e-verification defect immediately upon notification. AO failed to issue mandatory notice u/s 143(2) and furnish reasons for reopening assessment, constituting jurisdictional defects not curable u/s 292BB. ITAT held these procedural failures fatal to reassessment proceedings, relying on Hotel Blue Moon and CIT vs Trend Electronics precedents establishing that absence of s.143(2) notice invalidates assumption of jurisdiction and non-furnishing of reopening reasons renders reassessment proceedings void. Reassessment proceedings quashed.
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