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    <title>2022 (3) TMI 1466 - BOMBAY HIGH COURT</title>
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    <description>HC held that a notice under section 148 was invalid where it was issued by an ITO who admitted lack of jurisdiction and procedural migration of the PAN to the correct charge was not completed. The court ruled a section 148 notice is jurisdictional and any inherent defect cannot be cured; since the issuing officer had no authority over the taxpayer, the notice was issued without legal authority and was set aside.</description>
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      <description>HC held that a notice under section 148 was invalid where it was issued by an ITO who admitted lack of jurisdiction and procedural migration of the PAN to the correct charge was not completed. The court ruled a section 148 notice is jurisdictional and any inherent defect cannot be cured; since the issuing officer had no authority over the taxpayer, the notice was issued without legal authority and was set aside.</description>
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