https://www.taxtmi.com/caselaws?id=792051 A reassessment cannot be sustained unless the Revenue proves valid issuance and service of the mandatory notice under section 143(2) of the Income-tax Act. Here, the reassessment record did not contain the notice, the RTI reply stated that its contents were not available in the system, and the departmental record created ambiguity between notice under section 143(2) and notice under section 148. Because the foundational jurisdictional requirement remained unproved, the defect was treated as going to the root of jurisdiction rather than as a technical irregularity. The reassessment was therefore held invalid and the assessment was quashed in favour of the assessee. en-us Wed, 22 Apr 2026 00:00:00 +0530 Fri, 22 May 2026 07:06:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792051 A reassessment cannot be sustained unless the Revenue proves valid issuance and service of the mandatory notice under section 143(2) of the Income-tax Act. Here, the reassessment record did not contain the notice, the RTI reply stated that its contents were not available in the system, and the departmental record created ambiguity between notice under section 143(2) and notice under section 148. Because the foundational jurisdictional requirement remained unproved, the defect was treated as going to the root of jurisdiction rather than as a technical irregularity. The reassessment was therefore held invalid and the assessment was quashed in favour of the assessee. Case-Laws Income Tax Wed, 22 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792051