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ITAT invalidated reassessment proceedings due to jurisdictional defects in notice issuance under s.148. ITO Ward 3(2), Bulandsahar transferred assessee's records to ITO Ward-Exemption, Ghaziabad on 08.04.2018, but improperly issued s.148 notice on 26.03.2018 after transferring jurisdiction. Revenue failed to establish valid jurisdiction of ITO Bulandsahar for notice issuance. Assessment completed by ITO Ghaziabad under s.144/147 was deemed void ab initio due to invalid initiating notice. Tribunal quashed reassessment order, holding that lack of proper jurisdiction at notice stage invalidated entire proceedings.
ITAT invalidated reassessment proceedings due to jurisdictional defects in notice issuance under s.148. ITO Ward 3(2), Bulandsahar transferred assessee's records to ITO Ward-Exemption, Ghaziabad on 08.04.2018, but improperly issued s.148 notice on 26.03.2018 after transferring jurisdiction. Revenue failed to establish valid jurisdiction of ITO Bulandsahar for notice issuance. Assessment completed by ITO Ghaziabad under s.144/147 was deemed void ab initio due to invalid initiating notice. Tribunal quashed reassessment order, holding that lack of proper jurisdiction at notice stage invalidated entire proceedings.
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