Assessing Officer’s issued notice under section 143(2) dated 01.09.2010 to Shri Lohia Gourishankar G having PAN No.AAKPL3064D . and not to the assessee (HUF) having PAN No.AAAHL3831L but to Shri Lohia which makes it clear cut instance of non-issuance of a valid section 143(2) notice held to be mandatory condition in the foregoing landmark decision.

Accordingly Hon ITAT Pune quashed the impugned assessment for this precise legal reason alone.