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The only question that arises for our consideration in this batch of appeals is: whether service of notice on the assessee under s. 143(2) within the prescribed period of time is a prerequisite for framing the block assessment under Chapter XIV-B of the IT Act, 1961 ?

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Section 143(2), 143(3) & 292BB of the Income Tax Act, 1961 — Assessment — Notice under section 143(2) is mandatory for the purpose of making the assessment under section 143(3). Condition precedent for the applicability of section 292BB is that the notice must have emanated from the Department. Said section is not intended to cure complete absence of notice. there being absence of notice under section 143(2). assessment was invalid — Commissioner of income tax vs. Laxman Das Khandelwal [2019] 310 CTR (SC) 8

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