Notice u/s 143(2) was invalid as the same issued by another AO to whom jurisdiction was transferred much later

ACIT Vs Rajnil Sales Pvt. Ltd. (ITAT Delhi)

Conclusion: Notice under section 143(2) could be issued only by the jurisdictional AO within the time limit of issuing notice prescribed under the law. The jurisdiction over assessee was with the ITO Ward/Circle -9(3) Kolkata and not with the ACIT, Central Circle-14. Therefore, the notice issued by the ACIT, Central Circle-14 was invalid and without jurisdiction.

Held: The case of the assessee was selected for scrutiny assessment and notice under section 143(2). After the search and seizure operati

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