Delhi high court landmark decision on sec.143 (2) held “What is relevant for the present case is that prior to issuance of the notice under Section 143(2) (ii) the AO has to form an opinion that it is ‘necessary or expedient’ to ensure that an Assessee has not (i) understated the income or (ii) has not computed excessive loss, or (iii) has not underpaid the tax in any manner. The AO is, therefore, not expected to issue a notice under Section 143 (2) (ii) in a routine or casual or mechanical manner”
IN THE HIGH COURT OF DELHI AT NEW DELHI
W.P.(C) 5818/2013
HYOSUNG CORPORATION
versus
THE AUTHORITY FOR ADVANCE RULINGS & ANR
06.04.2016