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Section 148 Notice Without Jurisdiction Renders 263 Unsustainable
Case Law Details
- Case Name
- Nirmaben Sureshkumar Patel Vs ITO (ITAT Ahmedabad)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2017-18
- Courts
- All ITAT, ITAT Ahmedabad
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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 investme...
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