#Section 143(2) Income Tax Act

The ITAT Kolkata has ruled that failure to issue a Section 143(2) notice at all renders reassessment proceedings null and void, and the curative provision under Section 292BB does not apply to complete non-issuance - only defective service. This clarifies a critical jurisdictional safeguard for assessees, reinforcing that procedural compliance is non-negotiable in tax reassessments.

ITAT Delhi quashed an assessment order after the Assessing Officer failed to issue a Section 143(2) notice within the statutory six-month period from the end of the relevant previous year. The ruling reinforces strict compliance with CBDT Instruction No. 1/2011, invalidating assessments based on belated notices.