Assessment Reopening Invalid: ITO Lacked Jurisdiction After Legal Transfer in 2012, Section 124(3) Not Applicable. CIT Challenge Fails.

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....Validity of reopening of assessment - jurisdiction of ITO - In the appellant's case, the provision of section 124(3) does not come into play since the case of the assessee was legally transferred by the competent authority u/s. 127 as far back as in the year 2012. - Section 124(3) of the Act does not come into play in this case and so in no way help the Department to justify the action of ITO, Ward-5(3), Kolkata in issuing statutory notices to the assessee, which action itself was without jurisdiction. So the challenge raised by the Ld CIT, DR fails. - AT....