Section 148 notice issued by non-jurisdictional Assessing Officer was without jurisdiction

Pavan Morarka Vs ACIT (Bombay High Court) Respondent’s stand that the Assessing Officer at New Delhi had issued a notice under Section 148 of the said Act on petitioner on 22nd March 2013 before the limitation period expired and, therefore, the impugned notice issued by the Assessing Officer at Mumbai in continuation of the said proceedings must also be treated as valid and within time is misconceived. This is because we notice that the notice issued by the Assessing Officer at New Delhi itself was invalid and of no effect since it was issued by an officer who did not have jurisdiction over ...