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    <title>2025 (3) TMI 1267 - ITAT DELHI</title>
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    <description>A reassessment notice issued on 01.04.2021 was treated as falling under the substituted reassessment regime then in force, so completion of reassessment without the fresh procedure of enquiry, opportunity to respond, and consideration of the assessee&#039;s reply was said to be beyond jurisdiction and bad in law. For the later assessment years, where returns were filed in response to section 148 notices, the absence of notice under section 143(2) was treated as fatal because such notice is mandatory for assessment under section 143(3) read with section 147, and section 292BB does not cure a complete absence of notice. The article states that these jurisdictional defects rendered the reassessments void.</description>
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      <link>https://www.taxtmi.com/caselaws?id=767881</link>
      <description>A reassessment notice issued on 01.04.2021 was treated as falling under the substituted reassessment regime then in force, so completion of reassessment without the fresh procedure of enquiry, opportunity to respond, and consideration of the assessee&#039;s reply was said to be beyond jurisdiction and bad in law. For the later assessment years, where returns were filed in response to section 148 notices, the absence of notice under section 143(2) was treated as fatal because such notice is mandatory for assessment under section 143(3) read with section 147, and section 292BB does not cure a complete absence of notice. The article states that these jurisdictional defects rendered the reassessments void.</description>
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