Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Revision u/s 263 by CIT-A - Jurisdiction of AO - invalid notice u/s 143(2) - The issuance of notice u/s 143(2) is governed by statutorily prescribed procedures. On a combined reading of Sections 120(1), 120 (2), 124(1), Rule 12E of the IT Rules, 1962 and transfer order passed by CIT under Section 127 of the Act, we have no hesitation to hold that there was no valid jurisdiction available whatsoever with the Assessing Officer, Kolkata in the instant case. The notice issued under Section 143(2) of the Act by such officer is thus wholly without jurisdiction and thus a non-est notice. - AT
Revision u/s 263 by CIT-A - Jurisdiction of AO - invalid notice u/s 143(2) - The issuance of notice u/s 143(2) is governed by statutorily prescribed procedures. On a combined reading of Sections 120(1), 120 (2), 124(1), Rule 12E of the IT Rules, 1962 and transfer order passed by CIT under Section 127 of the Act, we have no hesitation to hold that there was no valid jurisdiction available whatsoever with the Assessing Officer, Kolkata in the instant case. The notice issued under Section 143(2) of the Act by such officer is thus wholly without jurisdiction and thus a non-est notice. - AT
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