Puspanjali Mishra (Smt.) v. ITO (2021) 210 TTJ 246 / 199 DTR 261 (SMC) (Cuttack) (Trib.)

S. 148 : Reassessment-Notice-No reasons are recorded and served before issuing the notice-Re assessment proceedings and consequential orders are quashed. [S. 143(2), 147]

Reassessment made by the Assessing Officer without issuing notices under section 143(2) being pure question of law can be challenged by filing additional ground before the Appellate Tribunal. Tribunal held that on facts no reasons are recorded and served before issuing the notice, therefore reassessment proceedings and consequential orders are quashed. (AY. 2012-13)