2025 (2) TMI 1982

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....el/2024 for AY 2012-13 arises out of the order of the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as 'ld. NFAC', in short] in Appeal No. ITBA/NFAC/S/250/2023- 24/1062959576(1) dated 19.03.2024 against the order of assessment passed u/s 147/143(3) of the Income-tax Act, 1961 dated 27.12.2019 (hereinafter referred to as 'the Act') by ITO, Ward-4, Hisar (hereinafter referre....

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....43(2) of the Act to the assessee after the assessee had filed his return of income on 27.12.2019. The reassessment order was framed u/s 147/143(3) of the Act by the ld AO on 27.12.2019 (i.e on the date of filing of return of income itself). Hence, it is amply clear that no notice u/s 143(2) of the Act at all was issued by the ld AO before completion of reassessment proceedings which becomes fatal ....