Addl CIT cannot exercise powers of AO without valid jurisdictions U/s. 120(4)(b

ACIT-2(3) Vs M/s Tata Sons Ltd., Bombay House (ITAT Mumbai)

Conclusion- In the absence of a valid order u/s 120(4)(b) as well as section 127(1) of the Act the Additional Commissioner of Income Tax could not have exercised powers of an Assessing Officer to pass the impugned assessment order.

Facts –

Assessee raised additional ground before the Tribunal stating that the assessment order cannot be passed by any officer without authority of law. Assessee contended that the additi

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