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Returns filed after the period stated in a reassessment notice are not non est where no statutory embargo applies; they must be recognised as returns in the reassessment proceedings. Once a return is on record in response to a notice under Section 142(1), issuance and service of notice under Section 143(2) are mandatory. Absence of that statutory notice creates a procedural defect that invalidates the reassessment assessment and prevents it from standing.
Returns filed after the period stated in a reassessment notice are not non est where no statutory embargo applies; they must be recognised as returns in the reassessment proceedings. Once a return is on record in response to a notice under Section 142(1), issuance and service of notice under Section 143(2) are mandatory. Absence of that statutory notice creates a procedural defect that invalidates the reassessment assessment and prevents it from standing.
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