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    <title>2024 (2) TMI 542 - ITAT KOLKATA</title>
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    <description>The Tribunal allowed the appeal, quashing the assessment order due to a jurisdictional error in the re-opening notice issued under section 148 of the Income Tax Act. The notice was invalid as it was issued by an ITO without territorial jurisdiction over the assessee, who was based in Kolkata, not Jaipur. The appeal, initially time-barred by 55 days, was allowed after condonation of delay, attributed to a communication gap in the faceless disposal process, with no mala fide intent found. The appeal proceeded on merit, resulting in a decision favorable to the assessee.</description>
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      <description>The Tribunal allowed the appeal, quashing the assessment order due to a jurisdictional error in the re-opening notice issued under section 148 of the Income Tax Act. The notice was invalid as it was issued by an ITO without territorial jurisdiction over the assessee, who was based in Kolkata, not Jaipur. The appeal, initially time-barred by 55 days, was allowed after condonation of delay, attributed to a communication gap in the faceless disposal process, with no mala fide intent found. The appeal proceeded on merit, resulting in a decision favorable to the assessee.</description>
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