Section 147, 263 of Income Tax Act, 1961—In the instant case, Assessee challenged the Orders u/s 263 of the I.T. Act, 1961.

Held that— In the present case, no notice under section 143(2) have been issued for completion of the re-assessment proceedings and that incorrect facts have been recorded in the reasons for reopening of the assessment. Therefore, the reassessment proceedings are invalid, bad in law and non-est and as such, liable to be quashed. We, therefore, following the reasons for decision in the cases of M/s. Supersonic Technologies Pvt. Ltd., M/s. SPJ Hotel Private Ltd., and M/s. Shiv Sai Infrastructure (P) Ltd., (supra), set aside the impugned Order of the Ld. Pr. CIT passed under section 263 of the I.T. Act and quash the same. Accordingly, appeal of the assessee is allowed.[M/S. SUPERSONIC TECHNOLOGIES PVT. LTD., M/S. SPJ HOTELS PRIVATE LIMITED, M/S. SHIV SAI INFRASTRUCTURE (P) LTD. M/S. SUPERIOR BUILDWELL PRIVATE LIMITED VERSUS THE PCIT-8, NEW DELHI.] [2018] 8 ITCD Online (34) [ITAT DELHI]