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Reassessment notices issued u/s 148 for assessment years 2018-19, 2019-20, and 2020-21 were time-barred by limitation. Withdrawal of approval u/s 10(23C)(vi) by the Principal Commissioner of Income Tax (PCIT) was invalid as there were no valid pending proceedings before the Assessing Officer. The second proviso to section 143(3), allowing the Assessing Officer to make a reference, was applicable only from assessment year 2022-23 onwards. The PCIT lacked jurisdiction, as the Commissioner (Exemption) with territorial jurisdiction should have approved or withdrawn the approval. The Appellate Tribunal decided in favor of the assessee, quashing the PCIT's orders withdrawing approval u/s 10(23C)(vi) due to lack of jurisdiction and invalid reassessment proceedings.
Reassessment notices issued u/s 148 for assessment years 2018-19, 2019-20, and 2020-21 were time-barred by limitation. Withdrawal of approval u/s 10(23C)(vi) by the Principal Commissioner of Income Tax (PCIT) was invalid as there were no valid pending proceedings before the Assessing Officer. The second proviso to section 143(3), allowing the Assessing Officer to make a reference, was applicable only from assessment year 2022-23 onwards. The PCIT lacked jurisdiction, as the Commissioner (Exemption) with territorial jurisdiction should have approved or withdrawn the approval. The Appellate Tribunal decided in favor of the assessee, quashing the PCIT's orders withdrawing approval u/s 10(23C)(vi) due to lack of jurisdiction and invalid reassessment proceedings.
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