Appellate enhancement limits protect against new income sources, while documented credits and prior-year investments resist unexplained-income additio...
Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
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The ITAT Kolkata ruled on the validity of an assessment order u/s 147. The jurisdictional AO did not issue a valid notice u/s 148. The assessee argued that the ACIT lacked jurisdiction and a fresh notice should have been issued by the correct authority. Since no such notice was issued, the assessment proceedings were deemed illegal and void ab initio. The ITAT held that without a valid notice u/s 148, the reassessment proceedings were bad in law and quashed them, deleting the additions made. The appeal by the assessee was allowed.
The ITAT Kolkata ruled on the validity of an assessment order u/s 147. The jurisdictional AO did not issue a valid notice u/s 148. The assessee argued that the ACIT lacked jurisdiction and a fresh notice should have been issued by the correct authority. Since no such notice was issued, the assessment proceedings were deemed illegal and void ab initio. The ITAT held that without a valid notice u/s 148, the reassessment proceedings were bad in law and quashed them, deleting the additions made. The appeal by the assessee was allowed.
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