Held that non-issuance of notice u/s 143(2) is a jurisdictional defect and cannot be cured by section 292BB. Reassessment is held to be bad in law. Relied on CIT v. Laxman Das Khandelwal (SC). (AY. 2009-10, 2010-11, 2011-12)
Sapankumar U. Jain v. ITO (2022) 94 ITR 216 (Mum.)(Trib.)
S. 143(2) : Assessment-Notice-Non-issuance of notice u/s 143(2) is a jurisdictional defect and cannot be cured by section 292BB-Reassessment is held to be bad in law. [S. 147, 148, 292BB]