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Judgment
This assessee’s appeal for assessment year 2015-16, arises against the National Faceless Appeal Centre (NFAC), Delhi [in short, the “NFAC”], dated 10.02.2026 involving proceedings under section 147/144 of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).
Heard both the parties. Case file perused.
Coming to the first and foremost legal issue between the parties, it is revealed from a perusal of the case records that though the assessee had filed his return of income on 20.01.2022 in compliance to Section 148 notice herein dated 28.03.2021, the learned Assessing Officer does not appear to have issued any section 143(2) notice which has been held mandatory in ACIT Vs. Hotel Blue Moon [2010] 321 ITR 362 (SC). This being the clinching illegality found in the impugned assessment, the same is quashed in very terms. Ordered accordingly.
All other pleadings between the parties on merits stands rendered academic.
This assessee’s appeal is allowed.