Reassessment Notice Issued by Wrong Authority – ITAT Quashes Entire 148 Proceedings Following P&H HC

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 ...