Section 148 Assessment Set Aside Over Jurisdiction & DIN Defects

Amit Dattatraya Amrutkar Vs ITO (ITAT Pune)

Jurisdiction, DIN & 148 Defects Ignored- Failure to Decide Key Legal Ground Costs CIT(A): Pune ITAT Sets Aside Entire Order

Assessee challenged assessment framed u/s 144 r.w.s 263 for AY 2011-12 & raised multiple legal grounds including absence of DIN, wrong jurisdictional AO issuing notice u/s 148, failure to issue fresh notice after transfer, & consequential invalidity of order passed u/s 144 r.w.s 263.

Tribunal noted that assessee had specifically raised Ground No.2 in Form 35

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