2025 (9) TMI 99

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....i [the learned CIT (A)], failing to appreciate that the assessment was framed u/s 143(3) of the Income-tax Act, 1961 (the Act) dehors any notice u/s 143(2) of the Act being issued by the AO and accordingly, the assessment framed dated 20.03.2025, u/s 143(3) of the Act is invalid, void ab initio and ex-facie null in law. 2.1. The facts in brief are that the assessee filed the return of income on 29.11.2012, declaring total income at Rs.2,070. The case of the assessee was selected for scrutiny under Computer Assisted Scrutiny Selection (CASS) and notice u/s 143(2) of the Act was issued on 29.08.2013. Thereafter the ld. AO issued notice u/s 142(1) of the Act along with questionnaire and called upon the assessee to furnish the details and ev....

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....ITO, Ward 34(1), Kolkata on 29.08.2013, a copy of which is available at page no.431 of the Paper Book. Thereafter the assessee wrote to the Commissioner of Income Tax, Kolkata-XII, Aayakar Bhawan Poorva, Kolkata, informing that the jurisdiction of the assessee has been allotted to ITO Ward-34(1)/ Kolkata, whereas being a private limited company jurisdiction lies with ITO Ward 4(1), Kol under CIT -II/Kol and accordingly, requested the commissioner to migrate the PAN in proper jurisdiction. However, thereafter the notice u/s 142(1) dated 10.02.2015, was issued by ITO Ward 4(3), Kolkata calling upon the assessee to furnish the various details and information which were accordingly, submitted also before the ld. AO. The ld. AR vehemently submit....