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    <title>2024 (11) TMI 1029 - ITAT PATNA</title>
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    <description>ITAT Patna held that reassessment notices issued under section 148 for AY 2018-19, 2019-20, and 2020-21 were time-barred by limitation. The tribunal quashed orders withdrawing approval under section 10(23C)(vi) as the AO&#039;s reference to PCIT was invalid - made during non-pending proceedings and under the second proviso to section 143(3) which was not applicable to the assessment years in question. Additionally, PCIT lacked territorial jurisdiction as Commissioner (Exemption) was the appropriate authority for approval/withdrawal matters. The case was decided in favor of the assessee.</description>
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    <pubDate>Wed, 20 Nov 2024 00:00:00 +0530</pubDate>
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      <title>2024 (11) TMI 1029 - ITAT PATNA</title>
      <link>https://www.taxtmi.com/caselaws?id=762043</link>
      <description>ITAT Patna held that reassessment notices issued under section 148 for AY 2018-19, 2019-20, and 2020-21 were time-barred by limitation. The tribunal quashed orders withdrawing approval under section 10(23C)(vi) as the AO&#039;s reference to PCIT was invalid - made during non-pending proceedings and under the second proviso to section 143(3) which was not applicable to the assessment years in question. Additionally, PCIT lacked territorial jurisdiction as Commissioner (Exemption) was the appropriate authority for approval/withdrawal matters. The case was decided in favor of the assessee.</description>
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