Manual Section 148 Notices Violate CBDT Escaping Assessment Scheme

Vivek Kumarasamy Vs ITO (ITAT Chennai)

JAO-Issued Notice- Faceless Breach Invalidates 148 Notice—Subject to Revival if Apex Court Overturns Hexaware Line

Assessee filed appeal with a delay of 73 days which Tribunal condoned. Assessee raised an additional legal ground that the notice u/s 148 dated 31.03.2023 issued by ITO, Ward 2(1), Erode (JAO) is without jurisdiction since CBDT Notification dated 29.03.2022 mandates that issuance of notice u/s 148 & reassessment u/s 147 shall be through automa

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