Jurisdiction by AO to suo-moto convert protective assessment...

Jurisdiction by AO to suo-moto convert protective assessment into substantive assessment post completion of original assessment proceedings - Once the ld CIT(A) was ceased of the matter, the AO could have brought this up before the ld CIT(A) and sought necessary directions. Where however, the AO still hold the belief to take suo-moto action to convert protective assessment into substantive assessment, he could have invoked his jurisdiction in terms of section 147 on satisfaction of conditions specified therein and in absence of thereof, the present action of the AO cannot be sustained in the eyes of law. - AT