2022 (12) TMI 1218

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....he present appeal has been preferred by the assessee against the order dated 28.06.2019 of the Commissioner of Income Tax (Appeals)-1, Chandigarh [hereinafter referred to as 'CIT(A)']. 2. The assessee in this appeal has taken following grounds of appeal : - 1. That the order of the Ld. Assessing Officer upheld by the Worthy CIT(A) is being challenged on the ground of it being bad in la....

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....al legal grounds of appeal :- 1. That the Notice issued under section 148 of the Act is bad in law and against the provisions of the Income Tax Act 1961 a) Ld. Principal CIT has recorded satisfaction in a mechanical manner, without application of mind to accord sanction for issuing of notice U/s 148 of the Act . b) Notice U/s 148 issued by Non Jurisdictional Assessing Of....

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....w on the facts that same were out of total turnover of the assessee. 4. Any other ground or grounds as may be urged at the time of hearing. The assessee inter alia has taken the legal ground that no notice u/s 148 was issued by the AO who has framed the assessment order. 4. Since this additional ground goes to the root of the case, therefore, the same is admitted for adjudication. ....

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....the name of the assessee was lying in the PAN Data Base of ITO, Ward-4(5), Chandigarh and since the l imitation to issue notice u/s 148 of the Act was going to expire, therefore, the AO / ITO with whom the name of the assessee way lying as per PAN Data Base issued notice u/s 148 of the Act . However, later on, the case was transferred to the concerned jurisdictional ITO, Ward-3(5) and the assessme....