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The Tribunal held that the reassessment proceedings were invalid because the AO failed to issue a notice under section 143(2) within the prescribed time limit. Consequently, the assessment order was quashed.
The Tribunal held that the notice issued by the AO under section 148 was barred by limitation as per the first proviso to section 149 of the Act. Consequently, the assessment order passed by the AO was quashed for want of valid assumption of jurisdiction.
The Tribunal held that the AO ought to have accepted and acted upon the belated return of income filed by the assessee. Furthermore, the assessment order passed without issuing a notice under section 143(2) of the Act is invalid.