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The Income Tax Appellate Tribunal quashed the assessment order u/s 144/147 and the demand notice u/s 156, treating them as non-existent due to the failure to mention the Document Identification Number (DIN) as per the CBDT circular. Additionally, the Tribunal held that the notice issued u/s 148 was invalid due to lack of proper application of mind and objective satisfaction by the higher authority while granting approval, following the Bombay High Court's decision in Teleperformance Global Service (P) Ltd. Consequently, the assessee's appeal was allowed.
The Income Tax Appellate Tribunal quashed the assessment order u/s 144/147 and the demand notice u/s 156, treating them as non-existent due to the failure to mention the Document Identification Number (DIN) as per the CBDT circular. Additionally, the Tribunal held that the notice issued u/s 148 was invalid due to lack of proper application of mind and objective satisfaction by the higher authority while granting approval, following the Bombay High Court's decision in Teleperformance Global Service (P) Ltd. Consequently, the assessee's appeal was allowed.
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