The reopening of an assessment cannot take place if only the notice under Section 148 of the Act is issued and no notice under Section 143(2) of the Act is issued prior to passing the reassessment order under Section 143 r.w.s 147 of the Act. The defect is not curable under Section 292BB of the Act. (AY. 2008-2009)
DCIT v. Board of Cricket Control in India (2021) 212 TTJ 937/ 205 DTR 257 (Mum.)(Trib.)
S. 147 : Reassessment-Reopening by issuing notice under Section 148 but no notice under Section 143(2)-Reassessment is bad in law. [S. 143(2), 292BB]