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    <title>2025 (3) TMI 21 - ITAT RAIPUR</title>
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    <description>Issuance of notice under Section 143(2) after a return is filed in response to Section 148 is presented as a mandatory jurisdictional requirement for a reassessment under Section 147. Absence of evidence that such notice was issued renders the reassessment invalid, and taxpayer participation cannot cure that defect. On this basis, the assessment was quashed. The challenge to allegedly mechanical approval for reopening under Section 151(1) was not finally determined. The substantive question whether land qualified for agricultural-land exemption from capital gains tax was also left open because the notice defect was dispositive.</description>
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    <pubDate>Wed, 09 Oct 2024 00:00:00 +0530</pubDate>
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      <title>2025 (3) TMI 21 - ITAT RAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=766636</link>
      <description>Issuance of notice under Section 143(2) after a return is filed in response to Section 148 is presented as a mandatory jurisdictional requirement for a reassessment under Section 147. Absence of evidence that such notice was issued renders the reassessment invalid, and taxpayer participation cannot cure that defect. On this basis, the assessment was quashed. The challenge to allegedly mechanical approval for reopening under Section 151(1) was not finally determined. The substantive question whether land qualified for agricultural-land exemption from capital gains tax was also left open because the notice defect was dispositive.</description>
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      <pubDate>Wed, 09 Oct 2024 00:00:00 +0530</pubDate>
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