Time barred notice under section 143(2) invalidates assessment where a revised return relates back and no notice was served.
X X X X Extracts X X X X
X X X X Extracts X X X X
....Validity of a notice under section 143(2) was contested on limitation and service grounds: the revised/rectified return filed later was held to relate back to the original return date, so the six month limitation for issuing a notice ran from the original filing and expired before the notice dated 22.09.2019; additionally no notice was served within the statutory period due to change of address/name/email, and because service of the section 143(2) notice is mandatory, the assessment was held void and quashed.....




TaxTMI
TaxTMI