ITAT allowed the assessee's appeal, holding that the notice...

ITAT allowed the assessee's appeal, holding that the notice issued u/s 143(2) was unsigned and blank, thereby violating s. 282A(1) of the Act. The Tribunal found no material from the Revenue to rebut this factual defect. Consequently, the notice u/s 143(2) was declared invalid, arbitrary, and void ab initio. As the foundational notice itself was void, the AO lacked valid inherent jurisdiction to frame the assessment u/s 143(3)/147 r.w.s. 263/144B. The resultant reassessment order was therefore quashed in entirety, granting full relief to the assessee.