Rajlaxmi Petrochem (P) Ltd v. ITO (2023) 224 TTJ 1004 (Pune)(Trib)

S. 147 : Reassessment-No sanction was recorded on the date of issuance of notice-Reassessment is not valid-Notice under section 143(2) is not issued-Reassessment is quashed.[ S. 143(2), 148, 149,151]

Held that the Assessing Officer issued the notice under section 148 on 31 st March 2017, where as the endorsement made by the PCIT on the letter is dt. 7 th April 2017, hence the reassessment is not valid. The Tribunal also held that the mandatory notice under section 143(2) is also not issued hence the reassessment is quashed. (AY. 2010-11)