Tax Reassessment Case: Importance of Issuing Section 143(2) Notice After Section 148 Notice for Valid Proceedings.

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....Reopening of assessment u/s 147- non-issue of notice u/s. 143(2) - Non filing of ITR within thirty days after issue of notice u/s. 148 - though the assessee did not file the return of income within the specified time given by AO, the assessee had filed the return of income before the reassessment was framed. - So, on a con-joint reading of section 148(1) with sec. 139(4) and section 144 makes it abundantly clear that pursuant to a notice u/s. 148 of the Act, if an assessee files belatedly a return or a letter reiterating his earlier return then the AO is bound to issue notice u/s. 143(2) of the Act, if he has to frame re-assessment order u/s 143(3)/144 of the Act.....