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Notice under section 143(2) is a mandatory jurisdictional condition for completing a section 153C assessment that departs from a return filed in response to the statutory notice. Complete non-issuance is not a procedural irregularity capable of cure through section 292BB. Applying the view favourable to assessees amid divergent non-jurisdictional decisions, assessments completed under section 153C read with section 143(3) without such notice were quashed. Challenges to additions and other merits remained unadjudicated.
Notice under section 143(2) is a mandatory jurisdictional condition for completing a section 153C assessment that departs from a return filed in response to the statutory notice. Complete non-issuance is not a procedural irregularity capable of cure through section 292BB. Applying the view favourable to assessees amid divergent non-jurisdictional decisions, assessments completed under section 153C read with section 143(3) without such notice were quashed. Challenges to additions and other merits remained unadjudicated.
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