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ITAT allowed assessee's appeal, holding the scrutiny assessment void ab initio due to an invalid notice under s.143(2) of the Income-tax Act. The notice, issued pursuant to computer-aided scrutiny selection, did not specify whether the case was taken up for limited scrutiny, complete scrutiny, or compulsory manual scrutiny, contrary to binding CBDT instructions. ITAT held that revenue authorities are mandatorily required to adhere to such instructions and that non-compliance vitiates the jurisdiction assumed by the Assessing Officer. Consequently, the impugned notice under s.143(2) and all consequential assessment proceedings were declared invalid, and the matter was decided in favour of the assessee.
ITAT allowed assessee's appeal, holding the scrutiny assessment void ab initio due to an invalid notice under s.143(2) of the Income-tax Act. The notice, issued pursuant to computer-aided scrutiny selection, did not specify whether the case was taken up for limited scrutiny, complete scrutiny, or compulsory manual scrutiny, contrary to binding CBDT instructions. ITAT held that revenue authorities are mandatorily required to adhere to such instructions and that non-compliance vitiates the jurisdiction assumed by the Assessing Officer. Consequently, the impugned notice under s.143(2) and all consequential assessment proceedings were declared invalid, and the matter was decided in favour of the assessee.
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