ACIT's Assessment Invalid: Lacked Pecuniary Jurisdiction and Failed to Issue Mandatory Section 148 Notice for Reassessment.

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....Reopening of assessment u/s 147 - Jurisdiction of Income Tax Authorities - Power to transfer cases - the assessment framed by ACIT, Circle-23(1), Hooghly, is bad in law on two counts, firstly he did not have any pecuniary jurisdiction to frame the assessment and secondly he himself did not form any belief that the income of the assessee has escaped assessment nor did he issue notice u/s 148 of the Act which was sine qua non to assume jurisdiction to frame to assessment. - AT....