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Reassessment Notice Issued by Wrong Authority – ITAT Quashes Entire 148 Proceedings Following P&H HC
Case Law Details
- Case Name
- Harmit Kaur Vs ITO (ITAT Chandigarh)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2020-21
- Courts
- All ITAT, ITAT Chandigarh
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Harmit Kaur Vs ITO (ITAT Chandigarh)
Assessee challenged the very jurisdiction of the reassessment proceedings on the ground that the notice u/s 148 dated 26.03.2024 was issued by the Jurisdictional AO, even though CBDT Notification No.18/2022 dated 29.03.2022 (issued u/s 151A) mandates that ONLY NFAC/NPAC can issue notices u/s 148 & 148A.
CIT(A) dismissed the appeal on limitation without deciding this pure legal ground.
Before the ITAT, Assessee relied on binding judgments of the Punjab & Haryana High Court in:
Jatinder Singh Bhangu (19.07.2024)
Jasjit Singh (29.07.2024)
Satpal Kaur ...
Author Info
