Section 148 Notice Without Jurisdiction Renders 263 Unsustainable

Nirmaben Sureshkumar Patel Vs ITO (ITAT Ahmedabad) Non-Jurisdictional AO Issued 148 Notice-  263 Order Set Aside—PCIT Must First Decide AO’s Jurisdiction Before Revising Assessee filed ROI declaring ₹4,81,320. Reassessment u/s 147 was completed by NFAC on 28.03.2022 accepting returned income. Subsequently, PCIT invoked revision u/s 263 based on search findings in Navratna Group indicating alleged on-money of ₹61,51,005 for a villa purchased by Assessee. PCIT held AO had done no enquiry regarding seized excel sheet, Settlement Commission disclosures, source of investment, applicability...