Faceless assessment notice must cover specific prejudicial variations; unexplained final additions without notice breach section 144B and natural just...
A scrutiny assessment was held invalid because the section 143(2) notice was issued by an officer lacking pecuniary jurisdiction under CBDT Instruction No. 1/2011. The return disclosed a loss above the limit assigned to the Income Tax Officer for metro charges, so jurisdiction vested in the Deputy Commissioner and not the ITO who issued the notice. The Tribunal treated the section 143(2) notice requirement as mandatory, not a curable procedural defect, and quashed the resulting assessment.
A scrutiny assessment was held invalid because the section 143(2) notice was issued by an officer lacking pecuniary jurisdiction under CBDT Instruction No. 1/2011. The return disclosed a loss above the limit assigned to the Income Tax Officer for metro charges, so jurisdiction vested in the Deputy Commissioner and not the ITO who issued the notice. The Tribunal treated the section 143(2) notice requirement as mandatory, not a curable procedural defect, and quashed the resulting assessment.
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