The legal necessity to issue notice u/s 143(2) arises where the AO considers it necessary or expedient to ensure that the assessee has not misstated the income in any manner. Where the return filed by the assessee has been accepted and the reassessment order has been passed u/s. 147 accepting the returned income and there is no addition made by the Assessing officer to the returned income, it was held that there was no necessity for the AO to call for the explanation from the assessee and for the purposes, issue notice u/s. 143(2) of the Act. (AY. 2013-14)
Bhaval Synthetics (India) Ltd. v. Dy. CIT (2020) 196 DTR 265 / 208 TTJ 937 (Jaipur)(Trib.)
S. 143(2) : Assessment-Notice-Income returned in pursuance of notice issued u/s. 148 was accepted-Requirement of issue of notice u/s. 143(2) is not required-Assessment is valid. [S. 147, 148]