https://www.taxtmi.com/caselaws?id=449594 ITAT Raipur held that an assessment order passed under sections 147 and 143(3) without issuing mandatory notice under section 143(2) is invalid and void ab initio. The tribunal ruled that a belated return filed in response to section 148 notice, if acknowledged and e-verified by the department, cannot be treated as non-est merely due to delay. Since the assessment order was invalid due to non-issuance of section 143(2) notice, the PCIT lacked jurisdiction to initiate revisionary proceedings under section 263, as such proceedings cannot be based on an invalid assessment order. en-us Wed, 22 Nov 2023 00:00:00 +0530 Fri, 03 Jul 2026 11:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449594 ITAT Raipur held that an assessment order passed under sections 147 and 143(3) without issuing mandatory notice under section 143(2) is invalid and void ab initio. The tribunal ruled that a belated return filed in response to section 148 notice, if acknowledged and e-verified by the department, cannot be treated as non-est merely due to delay. Since the assessment order was invalid due to non-issuance of section 143(2) notice, the PCIT lacked jurisdiction to initiate revisionary proceedings under section 263, as such proceedings cannot be based on an invalid assessment order. Case-Laws Income Tax Wed, 22 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449594