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    <title>2026 (1) TMI 696 - ALLAHABAD HIGH COURT</title>
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    <description>Reopening of assessment was challenged where reasons to believe prompting reassessment were not supplied and no notice under Section 143(2) was issued; assessing officer nevertheless computed income from figures in a physically filed return and the assessee subsequently e-verified it. The decision relies on precedent holding that omission to serve the Section 143(2) notice is not curable and its issuance cannot be dispensed with, resulting in adverse consequence for the revenue. The Tribunal and appellate authority had noted the assessing officers use of physical return data and the later e-verification but the defect proved decisive.</description>
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      <title>2026 (1) TMI 696 - ALLAHABAD HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=784940</link>
      <description>Reopening of assessment was challenged where reasons to believe prompting reassessment were not supplied and no notice under Section 143(2) was issued; assessing officer nevertheless computed income from figures in a physically filed return and the assessee subsequently e-verified it. The decision relies on precedent holding that omission to serve the Section 143(2) notice is not curable and its issuance cannot be dispensed with, resulting in adverse consequence for the revenue. The Tribunal and appellate authority had noted the assessing officers use of physical return data and the later e-verification but the defect proved decisive.</description>
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