In the result, the appeal of the assessee stands allowed for statistical purposes
Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria
reassessment proceeding under section 147 is altogether fallacious and not into existence at all. 5. BECAUSE no notice under section 143(2) has been served upon appellant within stipulated time, therefore the whole of the assessment proceeding is vitiated for want of valid jurisdiction. 6. BECAUSE the NFAC has erred in law and on facts in sustaining addition of Rs.39