https://www.taxtmi.com/caselaws?id=463105 The ITAT Delhi held that the reopening of assessment was invalid as the AO failed to issue mandatory notice u/s 143(2) after the assessee filed a return pursuant to notice u/s 142(1), rendering the assessment without jurisdiction and liable to be quashed. The AO's satisfaction note under s.147 was also found deficient, lacking specific recording of escapement of income before issuance of notice u/s 148. However, since escaped income for earlier years had already been assessed, the issue regarding validity of reopening for subsequent years was remanded to the CIT(A) for fresh consideration. en-us Wed, 04 Mar 2015 00:00:00 +0530 Wed, 06 Aug 2025 10:51:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463105 The ITAT Delhi held that the reopening of assessment was invalid as the AO failed to issue mandatory notice u/s 143(2) after the assessee filed a return pursuant to notice u/s 142(1), rendering the assessment without jurisdiction and liable to be quashed. The AO's satisfaction note under s.147 was also found deficient, lacking specific recording of escapement of income before issuance of notice u/s 148. However, since escaped income for earlier years had already been assessed, the issue regarding validity of reopening for subsequent years was remanded to the CIT(A) for fresh consideration. Case-Laws Income Tax Wed, 04 Mar 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463105