Wrong AO’s U/s 143(2) = Non-Est Assessment – U/s 263 & Consequential Order Also Collapse

Bullionline LLP Vs PCIT (ITAT Delhi) ITAT Delhi allowed all three appeals of Bullionline LLP for AY 2017-18, holding that the entire proceedings were vitiated at the threshold due to lack of jurisdiction at the stage of issuing notice u/s 143(2). The Tribunal found that the initial notice u/s 143(2) dated 08-08-2018 was issued by ITO Ward 6(1), Chandigarh, who never had territorial or pecuniary jurisdiction over the assessee, whose registered office and return were at Delhi. The assessee objected within time, yet no transfer order u/s 127 was ever passed. Only the records were transferred, whi...