Assessment time-barred u/s 153 due to missing competent-authority reference for Singapore exchange of information; assessment disallowed as barred by ...
Issuance of a notice under section 143(2) is a jurisdictional requirement where a return is filed belatedly in response to an inquiry; absence of that notice renders any assessment completed under section 144 void. The tribunal found no material proving service of the mandatory notice and, following existing precedent, held the assessment without such notice invalid and quashed the assessment order, allowing the taxpayer's appeal.
Issuance of a notice under section 143(2) is a jurisdictional requirement where a return is filed belatedly in response to an inquiry; absence of that notice renders any assessment completed under section 144 void. The tribunal found no material proving service of the mandatory notice and, following existing precedent, held the assessment without such notice invalid and quashed the assessment order, allowing the taxpayer's appeal.
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