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    <title>2022 (9) TMI 1018 - ITAT DELHI</title>
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    <description>A return filed in response to notice under section 148 was held not to be a return under section 119(2)(b), as no condonation or relief application had been moved and the return was also beyond the six-year limit referred to in CBDT Circular No. 9/2015. Once the return was treated as a response to the section 148 notice, issuance of notice under section 143(2) became mandatory before any variation to the returned income. Because no such notice was issued, the reassessment was non-compliant with the statutory requirement, and the additions made under section 69A were deleted.</description>
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      <description>A return filed in response to notice under section 148 was held not to be a return under section 119(2)(b), as no condonation or relief application had been moved and the return was also beyond the six-year limit referred to in CBDT Circular No. 9/2015. Once the return was treated as a response to the section 148 notice, issuance of notice under section 143(2) became mandatory before any variation to the returned income. Because no such notice was issued, the reassessment was non-compliant with the statutory requirement, and the additions made under section 69A were deleted.</description>
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