Notice u/s 263 Invalid as Issued by ITO Below PCIT Rank; No Delegation Allowed in Statute.

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....Revision u/s 263 - validity of notice as issued by the ITO who is below the rank of ld. PCIT - The statute never permitted in section 263 for delegation of power to the authority below for issuance of notice for initiation of proceedings. - The delegation if possible if permitted by the law. DR was unable to place any judgment against the submission of assessee. Accordingly, the notice issued U/s 263 is invalid. - AT....