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    <title>2023 (1) TMI 1504 - CALCUTTA HIGH COURT</title>
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    <description>An assessment under Section 143(3) was treated as invalid where the notice under Section 143(2) had not been issued by the jurisdictional Assessing Officer, because the defect went to the authority to complete the assessment. The objection was held to be a jurisdictional one, capable of being raised even at a later stage, since there can be no estoppel against law. On that basis, the Tribunal&#039;s view that the assessment was bad in law was upheld, and no substantial question of law arose.</description>
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      <description>An assessment under Section 143(3) was treated as invalid where the notice under Section 143(2) had not been issued by the jurisdictional Assessing Officer, because the defect went to the authority to complete the assessment. The objection was held to be a jurisdictional one, capable of being raised even at a later stage, since there can be no estoppel against law. On that basis, the Tribunal&#039;s view that the assessment was bad in law was upheld, and no substantial question of law arose.</description>
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