CIT Revision u/s 263: AO's Failure to Issue Mandatory Notice Invalidates Reassessment Order, Section 292BB Inapplicable.

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....Revision u/s 263 by CIT - defect of non-issuance of notice u/s. 143(2) - Section 292BB is only safeguarding the deficiency if any of the service/non-service of notice and it does not cure the omission of issuance of mandatory notice by the AO And since in this case, the AO has not issued the mandatory notice u/s. 143(2) of the Act as found by the Ld. Pr. CIT, the question of section 292BB coming to the rescue of the AO to pass the reassessment order does not arise. - AT....