Issuance of Re-Assessment Notice Prior To Supply Of Recorded Reasons U/s 147 Is Fatal Procedural Lapse: ITAT

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Issuance of Re-Assessment Notice Prior To Supply Of Recorded Reasons U/s 147 Is Fatal Procedural Lapse: ITAT

Direct Tax

Published on

08/12/2025

By Mariya Paliwala

Issuance of Re-Assessment Notice Prior To Supply Of Recorded Reasons U/s 147 Is Fatal Procedural Lapse: ITAT

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The Income Tax Appellate Tribunal (ITAT), Delhi Bench has held that the Issuance of notice under section 143(2) prior to supply of recorded reasons under section 147 of the Income Tax Act has been held to be a fatal procedural lapse vitiating the entire reassessment. The bench of Yogesh Kumar U.S. (Judicial Member) and S….

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Mariya Paliwala https://www.jurishour.in/

Mariya is the Senior Editor at Juris Hour. She has 7+ years of experience on covering tax litigation stories from the Supreme Court, High Courts and various tribunals including CESTAT, ITAT, NCLAT, NCLT, etc. Mariya graduated from MLSU Law College, Udaipur (Raj.) with B.A.LL.B. and also holds an LL.M. She started her career as a freelance tax reporter in the leading online legal news companies.

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Procedural Lapse

Issuance of Re-Assessment Notice Prior To Supply Of Recorded Reasons U/s 147 Is Fatal Procedural Lapse: ITAT

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