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    <title>2025 (7) TMI 445 - PUNJAB AND HARYANA HIGH COURT</title>
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    <description>The HC held that an assessment framed under section 143(3) was invalid as the mandatory notice under section 143(2)(ii) was not served within twelve months from the end of the month in which the return was furnished. The court found that while a questionnaire was issued on 09.04.1999 and served on 22.04.1999, the statutory notice under section 143(2) was not issued before the stipulated date. Following the SC precedent in Assistant Commissioner of Income Tax vs. Hotel Blue Moon, the court decided the question of law in favor of the assessee and rejected the revenue&#039;s argument against raising this issue at the appeal stage.</description>
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    <pubDate>Fri, 07 Mar 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=774377</link>
      <description>The HC held that an assessment framed under section 143(3) was invalid as the mandatory notice under section 143(2)(ii) was not served within twelve months from the end of the month in which the return was furnished. The court found that while a questionnaire was issued on 09.04.1999 and served on 22.04.1999, the statutory notice under section 143(2) was not issued before the stipulated date. Following the SC precedent in Assistant Commissioner of Income Tax vs. Hotel Blue Moon, the court decided the question of law in favor of the assessee and rejected the revenue&#039;s argument against raising this issue at the appeal stage.</description>
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