2019 (12) TMI 83

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....nue with Ms. Zehra Khan, Jr. Standing counsel O R D E R 1. The petitioner has preferred the present petition to assail the notice dated 31.08.2018 issued under Section 143 (2) of the Income Tax Act (hereinafter referred as 'Act') and further notices issued by the respondent on the basis of the said notice, on the ground that the same are without jurisdiction. 2. The case of the petitioner....

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.... the observations that the petitioner's PAN was decentralized to Circle 33 (1),CIT (ii), New Delhi and that upon restructuring of the department which was carried out in the year 2014, Circle 33 (1) (Pre-structuring) was redesignated as Circle 51 (1), PCIT-17, New Delhi. 4. The submission of the learned counsel for the petitioner is that apart from the petitioner's case, the case of her husband....

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....e under Section 143 (2), which was issued on 13.08.2018. He submits that such objection is therefore clearly barred under Section 124 (3) (a) which reads as under; "(3) No person shall be entitled to call in question the jurisdiction of an Assessing Officer- (a) where he has made a return 83[under sub-section (1) of section 115WD or] under sub-section (1) of section 139, after th....