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    <title>Mandatory notice in reassessment and proper draft assessment procedure under section 144C are jurisdictional requirements</title>
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    <description>Mandatory notice under section 143(2) was treated as a jurisdictional precondition for completing reassessment under section 147 read with section 143(3); because the records did not show issuance of such notice before the draft assessment stage, the reassessment was held invalid for want of jurisdiction. The Tribunal further held that a purported draft order under section 144C ceases to be a mere proposal where it already directs tax demand, interest, credit adjustment and penalty initiation; in substance it is a final assessment order passed contrary to the statutory scheme. On that basis, the draft orders, final assessments and consequential proceedings were quashed, and the remaining issues were left academic.</description>
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    <pubDate>Sat, 04 Jul 2026 08:15:43 +0530</pubDate>
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      <title>Mandatory notice in reassessment and proper draft assessment procedure under section 144C are jurisdictional requirements</title>
      <link>https://www.taxtmi.com/highlights?id=101391</link>
      <description>Mandatory notice under section 143(2) was treated as a jurisdictional precondition for completing reassessment under section 147 read with section 143(3); because the records did not show issuance of such notice before the draft assessment stage, the reassessment was held invalid for want of jurisdiction. The Tribunal further held that a purported draft order under section 144C ceases to be a mere proposal where it already directs tax demand, interest, credit adjustment and penalty initiation; in substance it is a final assessment order passed contrary to the statutory scheme. On that basis, the draft orders, final assessments and consequential proceedings were quashed, and the remaining issues were left academic.</description>
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      <pubDate>Sat, 04 Jul 2026 08:15:43 +0530</pubDate>
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