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Notice under section 143(2) was held time-barred and also issued before the jurisdictional transfer under section 127 took effect, so the Assessing Officer lacked authority when the notice was served. On that dual basis, the consequent assessment under section 143(3) was declared invalid and quashed. The Tribunal did not entertain the separate challenge to the transfer order under section 127.
Notice under section 143(2) was held time-barred and also issued before the jurisdictional transfer under section 127 took effect, so the Assessing Officer lacked authority when the notice was served. On that dual basis, the consequent assessment under section 143(3) was declared invalid and quashed. The Tribunal did not entertain the separate challenge to the transfer order under section 127.
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