Invalid Assessment Order Voids Revisionary Proceedings Due to Missing Notice; Late Returns Not Dismissed as Non-Est.

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....Revision u/s 263 against non-Est order - The ITAT held that, return filed beyond the prescribed time limit under notice u/s 148 should not be treated as non-est. - However, the Tribunal held that, the order passed u/s 147 r.w.s. 143(3) in the present case was invalid on account of non-issuance of notice u/s 143(2) by the Ld. AO which is an accepted fact discernible from the order of Ld. PCIT, wherein it has been impliedly observed that no notice u/s 143(2) was issued, stating that the issuance of notice u/s 143(2) is not required. - Consequently, the revisionary proceedings initiated u/s 263 are without appropriate jurisdiction with the Ld. PCIT, since, the same cannot be invoked on the foundation of an invalid/ void ab initio assessment order.....