Supreme Court rules mandatory notice required for income tax reassessment

The Supreme Court held that a notice under Section 143(2) of the Income Tax Act, 1961, is mandatory for reassessment proceedings under Section 147. A bench including Justice Sanjay Kumar and Justice Sanjeev Sachdeva dismissed appeals filed by the Revenue Authority, confirming that reassessment proceedings are invalid if this notice was not issued. The ruling upheld that the proceedings were vitiated even if the assessee cooperated with the process.

The decision clarifies the procedural requirements for the Revenue Authority when reopening assessments. It establishes that the failure to issue the mandatory Section 143(2) notice invalidates the reassessment, regardless of the assessee's participation.