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2018 (5) TMI 1722 - AT - Income TaxReopening of assessment - Validity of notice u/s 148 to make a reassessment u/s 147 - Jurisdiction of AO - Held that:- Assessee is a Korean citizen working with Hyundai Heavy Industries Co. Ltd. - no notice u/s 148 along with reasons for reopening was ever served upon the assessee; that the AO, Mumbai who has issued the notice u/s 148 was not having jurisdiction as only AO, Dehradun was having the jurisdiction as per Notification, even the notice issued by AO, Mumbai was never served upon the assessee - thus entire reopening proceedings and consequent reassessment is void ab initio - Decided in favor of assessee.
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