Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
After the assessee filed a return in response to notice under section 148, the ITAT held that issuance of notice under section 143(2) was mandatory before completing reassessment to the assessee's detriment. The Tribunal treated the omission as a jurisdictional defect, not a curable procedural irregularity, and held that section 292BB cannot cure the complete absence of notice, only defects in service where notice has already been issued. Since no section 143(2) notice was issued after the return was filed and acted upon, the reassessment order was annulled.
After the assessee filed a return in response to notice under section 148, the ITAT held that issuance of notice under section 143(2) was mandatory before completing reassessment to the assessee's detriment. The Tribunal treated the omission as a jurisdictional defect, not a curable procedural irregularity, and held that section 292BB cannot cure the complete absence of notice, only defects in service where notice has already been issued. Since no section 143(2) notice was issued after the return was filed and acted upon, the reassessment order was annulled.
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