Non-assumption of jurisdiction u/s. 153C doesn’t oust recourse to section 147: Delhi HC

PCIT Vs Naveen Kumar Gupta (Delhi High Court) Delhi High Court held that as AO didn’t assume jurisdiction under section 153C of the Income Tax Act, recourse to section 147 of the Income Tax Act for reassessment proceedings justified. Accordingly, appeal by revenue allowed. Facts- The Revenue has filed the present appeal u/s. 260A of the Income Tax Act, 1961 impugning an order dated 09.12.2021 passed by the Income Tax Appellate Tribunal. Notably, ITAT had allowed the appeal preferred by the respondent/assessee against an order dated 26.11.2019 passed by the Commissioner of Income Tax (Appeals...