https://www.taxtmi.com/caselaws?id=450591 The dominant issue was whether the limitation for issuing a scrutiny notice under s.143(2) runs from the original return-filing date or from the date a defect was cured under s.139(9). The Tribunal held that s.139(9) permits curing defects up to completion of assessment, and does not bar the AO from proceeding meanwhile; therefore, curing a defect does not shift the statutory limitation start date. Relying on the jurisdictional HC's interpretation that no fresh return is filed on curing defects, the Tribunal held the s.143(2) notice had to be issued within time computed from the original filing date. Since the notice was time-barred, the assessment was without jurisdiction and was quashed; the appeal was allowed. en-us Wed, 21 Feb 2024 00:00:00 +0530 Mon, 05 Jan 2026 12:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450591 The dominant issue was whether the limitation for issuing a scrutiny notice under s.143(2) runs from the original return-filing date or from the date a defect was cured under s.139(9). The Tribunal held that s.139(9) permits curing defects up to completion of assessment, and does not bar the AO from proceeding meanwhile; therefore, curing a defect does not shift the statutory limitation start date. Relying on the jurisdictional HC's interpretation that no fresh return is filed on curing defects, the Tribunal held the s.143(2) notice had to be issued within time computed from the original filing date. Since the notice was time-barred, the assessment was without jurisdiction and was quashed; the appeal was allowed. Case-Laws Income Tax Wed, 21 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450591