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2021 (10) TMI 618 - ITAT DELHIReopening of assessment u/s 147 - no notice u/s 143(2) was issued - HELD THAT:- As gone through the assessment order AO has simply stated that the notice u/s 148 was issued on 23.03.2016 after recording the reasons placed on record, consequently; notice u/s 142(1) was issued on 21.07.2016. From the assessment order, it is clear that no notice u/s 143(2) was issued which is mandatory condition for framing the assessment u/s 147 - the assessment was framed is without authority of law - therefore, hold that the assessment is bad in law and the same is hereby quashed. Have quashed the assessment order on the ground that no notice u/s 143(2) was issued, the other grounds on merit have become of academic in nature, hence not adjudicated - Appeal of the assessee is allowed.
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