2022 (5) TMI 629

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....referred to as 'the Act') and the consequent initiation of reassessment proceedings under Section 147 vide notice dated 31st March, 2022 issued by Respondent No.1 under Section 148 of the Act for the assessment year 2018-19, and all proceedings/actions consequent thereto. 2. Learned counsel for the Petitioner states that Respondent No.1 has ignored the preliminary objection of the Petitioner that there was no valid jurisdiction with Respondent No.1 (located at Jaipur) for issuance of notice dated 14th March, 2022 or proposed initiation of reassessment proceedings, since jurisdiction over the Petitioner (and the erstwhile amalgamating entity) lies solely with Respondent No.3 at New Delhi). In support of his contention, learned counsel for t....

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....Infratel Ltd.) (PAN-AADCB0274F) Vs. Income Tax Officer and Ors. for A.Y. 2018-19 -reg. The information was received on INSIGHT portal in High Risk Non PAN CRIU/VRU pertaining to- the FY 2017-18 .and Actionable Assessment Year 2018-19 uploaded by the DIT(I&CI), Jaipur and flagged by RMS regarding that assessee entering into a transaction of purchase of immovable property worth Rs.91,15,000/- situated at patta no.69 V.P.O. Nagar, tehsil Gudamalani, Barnmer. The information did not have PAN of the assessee and the address of the assessee mentioned as D34, Subhash Marg, G Business Park, 3rd Floor, C Scheme Jaipur pertains to the territorial jurisdiction of the undersigned AO. Further, the information was marked on INSIGHT Portal by the office....

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....O/W-6(2)/JPR/2022-23/41 dated 11.04.2022 (copy enclosed) for assessment proceedings and sent to the concerned AO through speed post which stands delivered to him on 18.04.2022 (copy of tracking of speed post is enclosed). The order u/s 148A(d) was drafted after due application of mind by the undersigned which was then sent for the approval of the PCIT2, Jaipur through proper channel. In this process the Addl. CIT, Range 6, Jaipur has also applied his mind and recommended the case as fit for reopening of the assessment. The specified authority accorded her approval vide letter no.Pr.CIT-2/ITO(Tech)/JPR/2021-22/2469 dated 31.03.2022 and forwarded to office vide letter of the Addl. CIT, Range-6, Jaipur vide no. Addl. CIT/R6/JPR/2021-22/2319 ....