Wrong AO’s U/s 143(2) = Non-Est Assessment – U/s 263 & Consequential Order Also Collapse

Bullionline LLP Vs PCIT (ITAT Delhi)

ITAT Delhi allowed all three appeals of Bullionline LLP for AY 2017-18, holding that the entire proceedings were vitiated at the threshold due to lack of jurisdiction at the stage of issuing notice u/s 143(2).

The Tribunal found that the initial notice u/s 143(

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