Pradeep Dayanand Kothari v. CIT (2020) 429 ITR 14/(2021) 277 Taxman 260 (Mad.)(HC)

S. 147 : Reassessment-Information from investigation wing-HSBC Bank located in Switzerland-Procedural irregularities-Cannot be raised first time before High Court. [S. 143(2), 148 , 260A, 292BB]

Dismissing the appeal the Court held that, that the facts recorded by the Commissioner (Appeals) in his order made it clear that procedure had been followed. There were proper issuance and service of notices under section 143(2). There was no procedural irregularity and the question of applying section 292BB of the Act would not arise. Procedural irregularity could not be canvassed for the first time before the High Court, as the assessee was never prejudiced earlier, and on the facts there was statutory compliance with the procedure under section 143. The order of reassessment was valid. (AY.2006-07, 2007-08)