SHARANJEET KAUR, RAIPUR,RAIPUR vs. INCOME TAX OFFICER, WARD 3(1), RAIPUR, RAIPUR

ITA 553/RPR/2026Status: DisposedITAT Raipur07 July 2026AY 2013-1418 pages
AI SummaryAllowed

What did the Tribunal hold?

The tribunal held that the absence of a notice under Section 143(2) before completing the reassessment under Section 147 read with Section 144B renders the assessment invalid and bad in law. This is a mandatory procedural requirement.

What were the facts?

The assessee's appeal was filed late by 117 days, which was condoned by the tribunal. The core issue was the validity of a reassessment completed under Section 147 read with Section 144B without issuing a notice under Section 143(2).

What were the issues?

Whether a reassessment framed under Section 147 read with Section 144B is valid if a notice under Section 143(2) was not issued to the assessee after filing of the return in response to a notice under Section 148.

Which sections of the Income-tax Act were involved?

Section 147,Section 144,Section 144B,Section 143(2),Section 148,Section 142(1)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RAIPUR BENCH “SMC”, RAIPUR

Before: SHRI PARTHA SARATHI CHAUDHURY

For Appellant: shri Praveen Khandelwal &
For Respondent: Shri Piyush Tripathi, Sr. DR
Hearing: 07.07.2026Pronounced: 07.07.2026

PER PARTHA SARATHI CHAUDHURY, JM The present appeal preferred by the assessee emanates from the order of the Ld.CIT(Appeals)/NFAC, Delhi dated 09.12.2025 for the assessment year 2013-14 as per the grounds of appeal on record.

2.

At the very outset, it is noted that the appeal is time barred by 117 days. That explaining the said delay, the Ld. Counsel for the assessee submitted condonation petition a/w. affidavit, dated 25.06.2026. The r

The order continues below.

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