https://www.taxtmi.com/caselaws?id=761330 ITAT Patna held that reopening of assessment under section 147 beyond four years was invalid as conditions precedent were not satisfied, with no allegation of material fact suppression. The tribunal also found that the notice issued by ITO Ward-2(1) Patna lacked proper jurisdiction. Both the AO's assessment order and CIT(A)'s appellate order were set aside as bad in law. The assessee's appeal was allowed on both jurisdictional and procedural grounds. en-us Wed, 06 Nov 2024 00:00:00 +0530 Fri, 08 Nov 2024 19:58:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761330 ITAT Patna held that reopening of assessment under section 147 beyond four years was invalid as conditions precedent were not satisfied, with no allegation of material fact suppression. The tribunal also found that the notice issued by ITO Ward-2(1) Patna lacked proper jurisdiction. Both the AO's assessment order and CIT(A)'s appellate order were set aside as bad in law. The assessee's appeal was allowed on both jurisdictional and procedural grounds. Case-Laws Income Tax Wed, 06 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761330