Reopening an assessment u/s 147 needs a Section 143(2) notice, dependent on assessee's return submission.
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....Reopening of assessment u/s 147 - no notice u/s 143(2) of the Act was issued - Furnishing of the return is a sine qua non for issuance of notice under Section 143(2) of the Act. If no return is furnished by the assessee, there can be no reason for issuance of notice under Section 143(2) of the Act....
TaxTMI