https://www.taxtmi.com/caselaws?id=409049 The ITAT Delhi held that the assessment order was void-ab-initio due to jurisdictional defects and time-barred notice under Section 143(2). The first notice was issued by a non-jurisdictional AO, and the jurisdictional AO's subsequent notice exceeded statutory time limits. No proper jurisdiction transfer occurred under Sections 120/124. Since the assessment itself was invalid, the Principal CIT's revision order under Section 263 became nullity. Additionally, the AO had adequately verified the Long Term Capital Gain exemption claim, making the Principal CIT's view merely a second opinion, which is impermissible under Section 263. The appeal was allowed. en-us Tue, 22 Jun 2021 00:00:00 +0530 Sat, 03 May 2025 12:28:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=409049 The ITAT Delhi held that the assessment order was void-ab-initio due to jurisdictional defects and time-barred notice under Section 143(2). The first notice was issued by a non-jurisdictional AO, and the jurisdictional AO's subsequent notice exceeded statutory time limits. No proper jurisdiction transfer occurred under Sections 120/124. Since the assessment itself was invalid, the Principal CIT's revision order under Section 263 became nullity. Additionally, the AO had adequately verified the Long Term Capital Gain exemption claim, making the Principal CIT's view merely a second opinion, which is impermissible under Section 263. The appeal was allowed. Case-Laws Income Tax Tue, 22 Jun 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=409049