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2016 (11) TMI 76 - KERALA HIGH COURT

2016 (11) TMI 76 - KERALA HIGH COURT - TMI - Reopening of assessment - non issue of notice u/s 143(2) - Held that:- We are unable to understand why a notice under Section 143(2) was not issued for the year 2009-10 when the same was issued for the year 2010-11. The order sheet, Annexure- A2 annexed along with the papers shows that the Assessing Officer was aware of the need for issuance of the said notice as early as in April 2012. The only reason for not issuing a Section 143(2) notice has been .....

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ssing Officer to issue a notice under Section 143(2) of the Act. This is more so because even in the absence of such an electronic return for the year 2010-11, the Assessing Officer had infact issued the mandatory notice for that year on 11.01.2012. - It is beyond comprehension that even though the Assessing Officer had time till 30.09.2011 to issue notice under Section 143(2) and even though he had recorded the reasons for assuming jurisdiction under Section 147 for re-assessment on 21.09. .....

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n but to hold in the absence of a Section 143(2) notice, proceedings of assessment initiated, conducted and completed for the year 2009-10 will have to fail but for the year 2010-11, since the proceedings have been continued on the basis of a validly issued Section 143(2) notice, same is being upheld. - I.T.A.Nos.221 & 228 of 2015 - Dated:- 19-10-2016 - Thottathil B.Radhakrishnan and Devan Ramachandran, JJ. FOR THE APPELLANT : ADVS.SRI.D.S.SREEKUMARAN, SMT.T.S.MAYA (THIYADIL) FOR THE RESPONDENT .....

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mply with the tax levies as long as certain inviolable criterion are met. As the society grows in complexity, especially in financial and fiscal areas, it may not be easy to design and administer a tax system that is fair and equitable in the absolute sense. However, our tax system would achieve an acceptable level of trust of its citizenry if it is generally seen as fair and equitable and this would be the desideratum that any society would aspire to obtain. 3. Perhaps, the most primary pre-req .....

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ayers are made to understand and put to notice about the detriment that the Act would inflict on them in case fiscal violation, evasion of tax or suppression of income are substantiated in the manner prescribed. It is when these safeguards and checks are perceived as being primary and inviolable that the system would achieve its most desired level of competence. 5. Taxation is a realm that is completely and absolutely authorised and defined by statute. No tax can be levied or collected except un .....

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es or monetary burdens are to be strictly construed is settled by the Hon'ble Supreme Court of India in a multitude of decisions and the above words of Rowlatt J. has found approval in them. It is the statutes of taxation that the maxim A verbis legis non est recedendum is the most apt and apodictic. This maxim directs the construction to be put on statutes, against the express letter of which the courts will not sanction any interpretation. 6. We have started this judgment with the above ex .....

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the appellant herein, is a company having a Diagnostics Laboratory at Kollam and a branch at Kottarakkara. The factual controversy starts straightaway, since the assessee maintains that the alleged branch at Kollam, which is having a Magnetic Resonance Imaging (MRI) Scan facility, is not owned by it but it is owned by another company by name M/s.Travancore Health Care (P) Ltd. and that it has no connection whatsoever with this company. The Revenue of course asserts otherwise and it is alleged th .....

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d the commission and professional fees to the doctors without deducting tax at source. Perhaps, as a response to the survey or being alerted of having to file their return to avoid further issues, the assessee, on 30.09.2009, filed their return of income under Section 139(1) of the Act for the assessment year 2009-10 declaring a total income at ₹ 1,58,519/-. The return for the year 2010-11 was subsequently filed, also under Section 139(1), on 14.10.2010. The return for the year 2009-10 was .....

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139(1), also to be a return in response to the notice under Section 148. It appears that thereafter, the case was posted for hearing on 19.12.2012 and that the assessee's authorised representative Sri.Alex Kuriakose, Chartered Accountant, appeared before the authorities and submitted certain details. A questionnaire under Section 142(1) of the Act was issued to Sri.Alex Kuriakose on 25.02.2013, and his answers shown to be sworn under oath, were furnished by him on 05.03.2013. Thereafter, the .....

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013. This was for the assessment year 2009-10. This order is annexed as Annexure-A4 along with ITA 221/2015. 9. As far as the next assessment year, namely A/Y 2010-11 was concerned, on the same set of allegations the Assessing Officer issued an assessment order under Section 143(3) of the Act dated 30.03.2013 assessing a total income of ₹ 1,43,52,665/-. This order is annexed as Annexure-A2 in ITA 228/2015. The assessment for the year 2010-11, as is perspicuous from Annexure-A2 was based on .....

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TVM/13-14 with respect to the assessment years 2009-10 and 2010-11 respectively. The appeals were heard by the Appellate Officer and by separate orders, both dated 25.03.2014, it was concluded that the Assessing Officer's estimation of income was based on mere presumptive ratios. He also came to the conclusion that the business of M/s.Travancore Health Care (P) Ltd. has been considered by the Assessing Officer to be that of the assessee though an incorrect interpretation of the statement of .....

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d to and the collection shown for this period in the books of accounts. With reference to the assessment year 2010-11, the appellate authority deleted all the additions made by the Assessing Officer. 11. As is expected, the Revenue carried the orders of the CIT (Appeals) in further appeals before the Income Tax Appellate Tribunal (ITAT), Kochi Bench, which were numbered as ITA Nos.289 and 290/Coch/14 for the assessment years 2009-10 and 2010-11 respectively. The assessee had also filed cross obj .....

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thority under Section 143(3) read with Section 147 of the Act, a notice under Section 143(2) of the Act had to be issued within the period of limitation. The assessee maintains that no such notice under Section 143(2) had ever been issued to him and that in such circumstances, the entire assessment fails. The assessee also raised an issue regarding the assumption of jurisdiction for assessment by the Assessing Officer under Section 147(1) which he claimed was without jurisdiction. It is the spec .....

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. 14. The ITAT, however, after considering each of the above issues, rejected all the contentions of the assessee and allowed the appeals filed by the Revenue holding that since the representative of the assessee had participated in the re-assessment proceedings under Section 147 and the assessment proceedings under Section 143, absence of issuance of notice under Section 143(2) would have no bearing and would stand condoned in view of Section 292BB of the Act and that there were valid cause and .....

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by the assessing authority is a bona fide estimate, based on rationale basis and concluded the total suppressed collection for the assessment year 2009-10 at ₹ 24,35,576/- as against ₹ 3,37,755/- assessed by the CIT(A). The ITAT then proceeded to estimate the suppressed receipts for the year 2010-11 adopting the same figures as were arrived at for the previous year. Since there was an increase of 24% per annum in the declared receipts for the year 2010-11 when compared to the assess .....

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sessment year 2010-11. Since the factual substratum of both these appeals are identical and arises out of the same set of incidents, we are proceeding to dispose of both the appeals by a common judgment. For the purpose of convenience, we are treating ITA 221/2015 as the case in lead and all the documents and references to parties, if not otherwise specifically mentioned, would be as per the reference made in ITA 221/2015. 16. We have heard Sri.D.S.Sreekumaran, the learned counsel appearing for .....

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questions of law, especially in the case of ITA 288/2015. 18. The questions that have been raised in ITA 228/2015 would also, according to our view, deal with the questions that have been raised in ITA 221/2015. The questions raised in ITA 221/2015 can be clubbed broadly into three classes. Question Nos.1 to 4 relate to the authority of the Assessing Officer to assume jurisdiction for re-assessment under Section 147 of the Act. Question No.6 relates to the service of notice under Section 143(2) .....

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son to believe that any income chargeable to tax has escaped assessment. The sweep of Section 147 has been stated with felicity by a Bench of this Court in Commissioner of Income Tax v. Abad Fisheries ((2012) 246 CTR 513). Paragraph 7 of the judgment declares the position succinctly and is extracted hereunder for immediate reference: So far as s.147 is concerned, in the first place, it is an income escaping assessment and it can be made for the first time as an assessment, no matter whether asse .....

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ommunicate reasons for initiating the income escaping assessment for any year against the assessee. Therefore, an income escaping asessment need not be based on return filed or the materials available therein or in the statement of accounts or documents attached thereto, but can be based on materials independently collected by the AO and available with him. In our view, s.147 is a distinct and separate power conferred on the AO to initiate action for assessment or reassessment and the only condi .....

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o returned or assessed. In other words, whether return is filed or intimation sent or regular assessment is completed or not, the AO can initiate and complete an assessment under s.147 for any year, if he has reason to believe that any income chargeable to tax has escaped assessment within the meaning of the said expression contained in the Act. As already stated, s.147 is a self-contained provision and the limitations and conditions are only those specifically stated therein. This position is f .....

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terials thereunder, but may be the materials independently collected leading to a subjective opinion in the minds of the Assessing Officer that he has reasons to believe that any income has escaped assessment with the only limitation that this shall be done within four years after the completion of assessment. The Assessing Officer has recorded the reasons for issuance of notice under Section 148 as under: a. A survey was conducted under Section 133A of the Act. b. The return of income under Sec .....

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nd it would become the foundational basis for the initial suspicion that the assessee had suppressed receipts for conducting MRI, CT Scan, etc. Further, though the assessee had issued receipts to the patients for conducting various tests, it was noticed during the survey that the copies of these receipts were not maintained in the books of account and that only ad hoc amounts were recorded in the books without any basis. It is also seen that there was variance between the actual receipts and dec .....

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Officer as under: 16. Section 147 authorizes and permits the Assessing officer to assess or reassess income chargeable to tax if he has reason to believe that income for any assessment year has escaped assessment. The word 'reason' in the phrase 'reason to believe' would mean cause or justification to know or suppose that income had escaped assessment, it can be said to have reason to believe that an income had escaped assessment. The expression cannot be read to mean that the As .....

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sential. At that stage, the final outcome of the proceeding, is not relevant. In other words, at the initiation stage, what is required is reason to believe, but not the established fact of escapement of income. At the stage of issue of notice, the only question is whether there was relevant material on which a reasonable person could have formed a requisite belief. Whether the materials would conclusively prove the escapement is not the concern at that stage. This is so because the formation of .....

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sdiction u/s. 147(a) two conditions were required to be satisfied firstly the Assessing officer must have reason to believe that income profits or gains chargeable to income-tax have escaped assessment, and secondly he must also have reason to believe that such escapement has occurred by reason of either (i) omission or failure on the part of the assessee to disclose fully or truly all material facts necessary for his assessment of that year. Both these conditions were conditions precedent to be .....

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147. The case at hand is covered by the main provision and not the proviso. 22. Continuing on the path of challenge of the authority of the Assessing Officer under Section 147 of the Act, Mr.Sreekumaran, the learned counsel for the appellant, further asserts that no notice under Section 148 of the Act could have been issued by the Assessing Officer when the returns filed by the assessee in response to the earlier notice under Section 142(1) was pending and not processed. This contention again h .....

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r issuing notice under s.143(2) for making regular assessment if the AO is of the view that materials available with him or discovered by him are such as to justify income escaping assessment under s.147, he is free to record the reasons for the belief and proceed to make income escaping assessment under s.147 without proceeding to make a regular assessment under s.143 (3) of the Act. The only caveat in the nature of a proscription noticed by this Court in Abad Fisheries (supra) while proceeding .....

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ed for assuming the jurisdiction vested in him under Section 147 of the Act and that the notice issued to him under Section 148 of the Act suffers from no legal error or infirmity. 24. Quoad hoc the contention of the appellant that the assessments for the years 2009-10 and 2010-11 have been made by the Assessing Officer without any discernable rationale and on conjunctures and surmises. We are of the considered view that the contention will not hold water. The assessments were made based on incr .....

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tions that were reflected in the impounded documents and the differance between the figures mentioned in those documents and the books of account maintained by the assessee which was justifiably found to be escaped and suppressed. Since the figures that were unearthed during the survey related to four months, the Assessing Officer then, on a pro-rata basis, adopted the same figures for the whole year and made an assessment for the year 2009-10. These figures were then extrapolated to the year 20 .....

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he representative to the questionnaire have no evidenciary value and that they cannot be used by the assessee for the purpose of assessment. He relies on the judgment of this Court in Paul Mathew and Sons v. CIT ((2003) 263 ITR 101 (Ker.)) and he placed before us paragraph 11 of the said judgment, which is as under: ......... we find that such a power to examine a person on oath is specifically conferred on the authorised officer only under s.132(4) of the IT Act in the course of any search or s .....

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ment recorded under s.133A of the IT Act, is not given any evidentiary value obviously for the reason that the officer is not authorised to administer oath and to take any sworn in statement which alone has the evidentiary value as contemplated under law. Therefore, there is much force in the argument of the learned counsel for the appellant that the statement, elicited during the survey operation has no evidentiary value and the ITO was well aware of this. 25. Before we examine this contention, .....

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and Sons was recorded. However, since the learned counsel for the appellant presses before us the same contention, we are contrained to answer it. For the purpose of this case, we do not think that it is necessary to venture into a question as to whether Paul Mathew and Sons lays down the right law. Even taking the dicta in Paul Mathew and Sons as the correct law, it is clear from the judgment that what this Court had said is that the statement made by the assessee under Section 133A of the Act .....

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ion or the statement will be at liberty to withdraw from the statement or admission, since such statement had not been made under Section 132(4), which provides for a sworn statement, but one under Section 133A of the Act. 26. In the case at hand, it is obvious that the statement made by the assessee was never resciled or recanted by it, but it continued to hold the statement to be correct throughout the proceedings. All that has been attempted to be done by the assessee is to show that the said .....

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account and that this has been the pattern in the branch at Kottarakkara also. Further, the pleadings in the appeal filed by the assessee before the CIT (Appeals), which is produced as Annexure-A5 to the papers in ITA 221/2015, would also show that the consistent case of the assessee is that even though separare bills are issued to the patients for MRI Scan and other diagnostic services, cash collection is done at one single point. On the end of the day, total income is separated and the income .....

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ord in order to arrive at an assessment. 27. The learned counsel for the appellant finally asserts that even if the documents impounded and the statement made are acceptable in evidence, the method adopted by the Assessing Officer and approved by the orders of ITAT in adopting the figures, found in the documents impounded, for the whole year on a prorata basis and the extrapolation of such figures for the subsequent year in order to make a best judgment or assessment is completely erroneous. We .....

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onale, since from the statement on behalf of the assessee the suppression was found to be continued. This method has already been found imprimatur by this Court in Commissioner of Income-Tax v. Dr.P.Sasikumar ((2016) 387 ITR 8 (ker)) as well as in the judgment of the Hon'ble Supreme Court in Commissioner of Sales Tax, Madhya Pradesh v. H.M.Esufali H.M.Abdulali ((1973) 90 ITR 271 (SC)). Even though the latter case relates to sales tax, the principles that have been stated therein would apply .....

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ave been given a statutory notice under Section 143(2) of the Act. We must say that this contention, in our mind, assumes great significance. The question as to whether a notice has to be issued under Section 143(2) before making an assessment or reassessment under the provisions of Sections 143 and 147 respectively is no longer res integra and is not untouched by dicta. The Hon'ble Supreme Court has answered this with precision in Assistant Commissioner of Income Tax v. Hotel Blue Moon ((20 .....

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sessing authority to issue notice under s.143(2) cannot be a procedural irregularity and the same is not curable and, therefor, the requirement of notice under s.143(2) cannot be dispensed with. 29. At the time when the matter was heard, the learned counsel for the Revenue virtually admitted that no notice under Section 143(2) of the Act has been issued but held out that even in the absence of Section 143(2) notice, the assessment made could be maintained on two grounds. He contends that the Ass .....

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tment Office of the Additional Commissioner of Income-tax Kollam Range, Kollam No.AACFT1116C/Cir.1/2011-12 Date: 10/12/2012 To M/s.Travancoe Diagnostics Pvt. Ltd. Chamakada, Najeem Complex, Kollam. Sub: Incometax Assessment in your own case-A.Y.2009-10 reg. Ref: Notice u/s. 143(2) dated 11/01/2012. .......... Sir, Income tax assessment for the A.Y. 2009-10 is posted for hearing at my office at Kollam on 19-12-12 at 3.30 p.m. You are requested to appear before me on the date of hearing either in .....

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t this is a notice that had been issued as a posting notice and nothing else. The above extracted notice ineffably refer to a notice under Section 143(2) dated 11.01.2012. However, the learned counsel for the Revenue took a defence that it was only a typographical error and in fact, refers to Section 148 notice that was issued on 11.01.2012. In any event of the matter, the fact that the above extracted notice can no way qualify itself to be a notice under Section 143(2) becomes obvious from the .....

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ot under-paid the tax in any manner, shall serve on the assessee a notice requiring him, on a date to be specifed therein, either to attend the office of the Assessing Officer or to produce, or cause to be produced before the Assessing Officer any evidence on which the assessee may rely in support of the return: Provided that no notice under this sub-section shall be served on the assessee after the expiry of six months from the end of the financial year in which the return is furnished. It is i .....

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Section 143(3) or a re-assessment under Section 147 (if the time for regular assessment is not over) will have to be rested on. In the absence of a notice under Section 143(2), it is obvious that no further proceedings can be continued for assessment under Section 143 and the Hon'ble Supreme Court has already settled the law that without such a notice the Assessing Officer could not assume jurisdiction and that this defect cannot be cured subsequently, since it is not a procedural defect, b .....

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f this Act, which is required to be served upon him, has been duly served upon him in time in accordance with the provisions of this Act and such assessee shall be precluded from taking any objection in any proceedin or inquiry under this Act that the notice was- (a) not served upon him; or (b) not served upon him in time; or (c) served upon him in an improper manner: Provided that nothing contained in this section shall apply where the assessee has raised such objection before the completion of .....

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as served upon him in an improper manner or that it was not served upon him in time. In this case, it is admitted by the assessee that his representative had appeared before the Assessing Officer on 19.12.2012, 11.03.2013 and 27.03.2013. The Revenue, therefore, asserts that since the assessee had appeared in the proceeding and had co-operated with the inquiry, he shall be then precluded from raising any contention that no notice had been served on him. This submission at the first blush appears .....

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sion that the proceedings that were going on was the re-assessment under Section 147 and not for assessment under Section 143 for the year 2009-10. We are not impressed with this stand of the assessee because as regards 2010-11, the assessee admits that the Revenue had issued a Section 143(2) notice and that the assessee had received the same. He was, therefore, obviously aware of the fact that the proceedings being continued were under Sections 143 and 147. However, the assessee is entitled to .....

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al irregularity and that the same is not curable and that therefore, the requirement of notice under Section 143(2) cannot be dispensed with. This emphatic statement of law, in the absence of issuance of a notice under Section 143(2) by the Revenue, would, therefore, inure to the benefit of the assessee, even though as noticed above, we are not impressed by the contention that he was not aware of the proceedings under Section 143 for the assessment year 2009-10. However, when the statute makes i .....

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d the mandatory notice, would the Revenue be entitled to the benefit provided under Section 292BB of the Act. Section 292BB creates an estoppel against the assessee in claiming that no notice has been served on him, if he has participated in the proceedings. However, the said section does not in any manner grant any privilege to the Assessing Officer in dispensing with the issuance of a notice under Section 143(2) of the Act. Since the jurisdiction under Section 143 is founded on the issuance of .....

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of Income Tax v. Greater Noida Industrial Development Authority ((2015) 379 ITR 0014 (All)), wherein it was held as under: Section 148(1) provides for service of notice as a condition precedent to making the order of assessment. Once a notice is issued within the period of limitation, jurisdiction becomes vested in the Income-tax Officer to proceed to reassess. The mandate of section 148(1) is that reassessment shall not be made until there has been service. The requirement of issue of notice is .....

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f estoppel contained therein only after a notice under Section 143(2) had been validly issued. When it is virtually admitted that no such notice had been issued, the Assessing Officer loses even the authority to enter into the jurisdiction under Section 143 and the participation or otherwise of the assessee would be of no avail. It is here that the words of Rowlat, J. vide supra in paragraph 5 of this judgment assumes climataric importance because in taxation nothing is to be intended and nothin .....

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year 2009-10 when the same was issued for the year 2010-11. The order sheet, Annexure- A2 annexed along with the papers in ITA 221/2015, shows that the Assessing Officer was aware of the need for issuance of the said notice as early as in April 2012. The only reason for not issuing a Section 143(2) notice has been recorded by him in the order sheet as it is not possible to generate notice under Section 143(2) through an AST, since the assessee has not filed the return electronically . The order .....

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