https://www.taxtmi.com/caselaws?id=784599 Where an assessee, in response to notice u/s 148, treats the original return u/s 139 as the return for reassessment, issuance and service of notice u/s 143(2) is a mandatory jurisdictional prerequisite to frame an order u/s 143(3) r.w.s. 147. Section 292BB, being a deeming provision curing defects in service, does not cure complete non-issuance of notice u/s 143(2). Resort to best judgment assessment u/s 144 was held impermissible when the return stood filed and no valid notice u/s 143(2) was issued. Consequently, the reassessment order u/s 144 r.w.s. 147 was vitiated as null and void, and the appeal was allowed. en-us Mon, 24 Nov 2025 00:00:00 +0530 Thu, 08 Jan 2026 08:22:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784599 Where an assessee, in response to notice u/s 148, treats the original return u/s 139 as the return for reassessment, issuance and service of notice u/s 143(2) is a mandatory jurisdictional prerequisite to frame an order u/s 143(3) r.w.s. 147. Section 292BB, being a deeming provision curing defects in service, does not cure complete non-issuance of notice u/s 143(2). Resort to best judgment assessment u/s 144 was held impermissible when the return stood filed and no valid notice u/s 143(2) was issued. Consequently, the reassessment order u/s 144 r.w.s. 147 was vitiated as null and void, and the appeal was allowed. Case-Laws Income Tax Mon, 24 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784599