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Judgment
ORDER
This assessee’s appeal for Assessment Year 2018-19 arises against the C IT(A)/NFAC, De lhi’ s DIN & order No. ITBA/NFAC/S/250/2025-26/1082375330(1) dated 07.11.2025, in proceedings u/s 147 r.w.s. 144 of the Income Tax Act, 1961 (in short “the Act”).
Heard both the p arties at length. Case file perused.
Coming to the assessee’s first and foremost legal ground, it emerges that there arises the fir st and foremost issue of validity of the impugned assessment dated 14.03 .2 023 itself for want of issuance of section 143(2) notice in furtherance to his return admitted ly filed on 28.03.2022.
That being the case, the Revenue could hardly dispute that even the learned assessing author ity has tabulated a list of all the opportunities given to the assessee wherein there is no such mention a notice issued u/s 143(2) of the Act forming a mandatory condition as per ACIT Vs. Hotel Blue Moon (2010) 321 ITR 362 (SC). I thus quash the impug ned assessment for the precise reason. Ordered accordingly .
All o ther remaining issue between the parties stand rendered acade mic.
This assessee’s appeal is allowed.
Order Pronounced in the Open Court o n 10/02/2026.