2020 (8) TMI 586

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.... Bhavnesh Saini, Judicial Member And Shri N.K. Billaiya, Accountant Member For the Assessee : Shri Rakesh Gupta, Advocate And Shri Sumit Jain, C.A. For the Revenue : Shri Sanjay Tripathi, SR DR ORDER PER BHAVNESH SAINI, J.M. The Departmental appeal as well as Cross Objection by Assessee are directed against the Order of the Ld. CIT(A)-3, Delhi, Dated 13.11.2015, for the A.Y. 2000- 2....

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....sessment as well as addition on merit before the Ld. CIT(A). The Ld. CIT(A) dealing with the objections of assessee regarding reopening of the assessment found that the assessee immediately on receipt of notice under section 148 contended before A.O. that notice under section 148 Dated 26.03.2007 is unsigned and did not mention the assessment year. The A.O. did not rebut the submissions of the ass....

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....e have been sent to the assessee, therefore, it vitiate the entire re-assessment proceedings because it was the jurisdictional notice to initiate proceedings under section 147 of the I.T. Act, 1961. Since the notice itself was illegal and bad in Law, therefore, entire re-assessment proceedings have been vitiated and as such A.O. could not have assume the jurisdiction under section 148 of the I.T. ....