https://www.taxtmi.com/caselaws?id=208851 Validity of reassessment proceedings turns on whether a notice under section 143(2) was served within the proviso period; the court found the notice issued beyond the six-month limit and therefore to be deemed not served, applying the principle that returns filed following a reopening notice require timely service of the 143(2) notice, with reliance on the Supreme Court precedent. The court held estoppel under statutory notice provisions inapplicable because no final assessment order was passed, quashed the reassessment proceedings, and directed issuance of an NOC to the foreign assessee for liaison office closure to meet RBI requirements. en-us Tue, 24 Jan 2012 00:00:00 +0530 Thu, 15 Jan 2026 14:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208851 Validity of reassessment proceedings turns on whether a notice under section 143(2) was served within the proviso period; the court found the notice issued beyond the six-month limit and therefore to be deemed not served, applying the principle that returns filed following a reopening notice require timely service of the 143(2) notice, with reliance on the Supreme Court precedent. The court held estoppel under statutory notice provisions inapplicable because no final assessment order was passed, quashed the reassessment proceedings, and directed issuance of an NOC to the foreign assessee for liaison office closure to meet RBI requirements. Case-Laws Income Tax Tue, 24 Jan 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208851