Reassessment Quashed for Issuing Section 148 Notice Through Wrong Authority

Anup Kumar Aggarwal Vs ACIT (Central) (ITAT Chandigarh) The assessee appealed against the order of the Commissioner of Income Tax (Appeals)-3, Gurgaon, dated 31 July 2025, for Assessment Year 2020-21. The original assessment had been completed under Section 147 on 12 March 2025 following a search conducted on the assessee-group on 4 November 2022. After the search, the case was centralized under Section 127 on 28 July 2023. A notice under Section 148 was subsequently issued on 29 December 2023 by the DCIT/ACIT (Central), Shimla, who was the Jurisdictional Assessing Officer (JAO). The assessee ...