Invalid Notice, Wrong Remand Report & PAN Errors: ITAT Orders Fresh Assessment

Savitri Devi Vs ITO (ITAT Delhi) Assessment u/s 144/147 Set Aside—CIT(A) Wrongly Relied on Remand Report of Another Year; PAN Deactivation & Non-Service of Notice Ignored Assessee’s PAN AGZPD4853H was deactivated by the Department. AO issued notices on a different PAN (AGGPD6250R), resulting in no service of notices and consequently non-compliance. AO completed best-judgment assessment u/s 144/147 on 28.11.2019, adding ₹23,35,532 (cash deposits ₹23,07,500 + other income) as unexplained. Before CIT(A), Assessee explained that PAN was deactivated, notices were never received, and sou...