Assessing Officer Must Issue Section 143(2) Notice Before Proceeding u/s 144 for Tax Return Assessment.

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....Best Judgement Assessment - whenever the return filed by an Assessee is not accepted at its face, it is mandatory for the AO has to issue a notice u/s 143(2) for proceeding further. It is thus not open for the AO to not issue a notice under Section 143(2) of the Act and proceed directly u/s 144 by rejecting the return filed by the Assessee. - HC....