Section 148 Notice quashed as Issuing Officer Had No Pecuniary Jurisdiction: ITAT Delhi

Advertisement DCIT Vs Alaka Mars Pvt. Ltd. (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT), Delhi dismissed the Revenue’s appeal after holding that the reassessment proceedings initiated under Sections 147 read with 143(3) were invalid because the notice under Section 148 had been issued by an Assessing Officer who lacked pecuniary jurisdiction under CBDT Instruction No. 1/2011. The Tribunal first condoned the 17-day delay in filing the Revenue’s appeal in the interest of justice before examining the jurisdictional issue raised by the assessee. The Tribunal noted that the ...