No notice under section 143(2) Notice – Assessment May Be Void
As per CBDT Circular No. F.No.225/157/2017/ITA-II dated 23.06.2017, any notice issued under Section 143(2) of the Income Tax Act, 1961 must clearly mention whether it pertains to:
(i) Limited Scrutiny (CASS)
(ii) Complete Scrutiny (CASS)
(iii) Compulsory Manual Scrutiny
If this classification is missing, the notice is invalid, and any assessment based on such a notice is also invalid. CBDT circulars issued u/s 119 are binding on the department.
This principle has been upheld in recent ITAT Kolkata Bench rulings:
Shib Nath Ghosh v. ITO (ITA No. 1812/KOL/2024)
Tapas Kumar Das v. ITO (ITA No. 1660/KOL/2024)
Sajal Biswas v. ITO (ITA No. 1244/KOL/2023)
The copy of the order is as under:
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