Income Tax Assessment u/s 147 Invalid Due to Missing Section 143(2) Notice; Section 292BB Offers No Relief.

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....Validity of the assessment framed u/s 147 - As the mandatory notice was not available in the records of the Revenue. Thus it can be inferred that the notice under section 143(2) of the Act was not issued by the Revenue. Thus in the absence of such mandatory notice, the proceedings initiated under section 147 of the Act are not maintainable and liable to be quashed. Provisions of section 292BB cannot extend any benefit to the revenue. - AT....