https://www.taxtmi.com/caselaws?id=791113 Once an assessee treats the original return as the return in response to notice under section 148, issuance of notice under section 143(2) becomes mandatory before reassessment is completed; absence of that notice creates a jurisdictional defect and the reassessment cannot stand. Reopening also cannot rest on investigation material framed only in tentative, probable, or presumptive terms without definite verification or a concrete factual link to the assessee. On both grounds, the reassessment was annulled and the Revenue's challenge failed; remaining grounds were left open. en-us Tue, 28 Apr 2026 00:00:00 +0530 Wed, 06 May 2026 08:32:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791113 Once an assessee treats the original return as the return in response to notice under section 148, issuance of notice under section 143(2) becomes mandatory before reassessment is completed; absence of that notice creates a jurisdictional defect and the reassessment cannot stand. Reopening also cannot rest on investigation material framed only in tentative, probable, or presumptive terms without definite verification or a concrete factual link to the assessee. On both grounds, the reassessment was annulled and the Revenue's challenge failed; remaining grounds were left open. Case-Laws Income Tax Tue, 28 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791113