Assessment under Section 143(3) invalidated for late notice beyond 12 months as per Section 143(2)(ii) rules

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....The HC invalidated the assessment framed under section 143(3) due to non-compliance with the mandatory notice requirement under section 143(2)(ii), as the notice was not served within twelve months from the end of the month in which the return was filed. The court relied on established Supreme Court precedent affirming the necessity of timely issuance of the notice. The respondent's objection to the framing of a substantial question of law at the hearing was dismissed, with the HC affirming its authority to frame such questions under section 260-A(4). Consequently, the question of law was decided in favor of the assessee, resulting in the quashing of the assessment order.....