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        Case ID :
        Income Tax

        ITAT held that a PCIT order under s.127 effected exclusive...

        s.127 transfer upheld despite ITBA delay; notice u/s 143(2) invalid, s.68 and s.115BBE additions deleted

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                ITAT held that a PCIT order under s.127 effected exclusive jurisdiction transfer to DCIT/ACIT, Central Circle-2, Madurai with effect from 09.12.2020; administrative delay in ITBA migration does not defer legal effect. Consequently, the ITO, Ward-4, Tirunelveli's notice issued u/s 143(2) on 29.06.2021 was without jurisdiction, invalid and liable to be quashed, rendering any resulting assessment order void ab initio. On merits, ITAT upheld the CIT(A)'s deletion of additions: an addition for alleged undisclosed business income based solely on survey notings was unsupported by corroborative evidence, and an addition u/s 68 read with s.115BBE was incorrect as amounts were opening balances, not credits in the year.
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