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2020 (10) TMI 795 - AT - Income TaxValidity of reopening of assessment u/s 147 - Jurisdiction of AO - as argued notice u/s 148 issued by the AO Jaipur without jurisdiction - HELD THAT:- Notice u/s 148 was issued by the ITO, Ward 2(2), Jaipur on 10.04.2014 after recording reasons at that time ITO, Ward 2(2), was not having jurisdiction over the case of assessee as the Director of the assessee has informed the ITO Ward-2(2), through telephone which is recorded by ITO, Ward-2(2). The Director of the company informed the AO that he is filing his return at Delhi and has already shifted his office at New Delhi and got its address changed in his PAN data wise and the same was also communicated to the assessee by the Income Tax PAN Services Unit vide its letter dated 26.03.2014 for change of address at New Delhi. Assessee has filed proves of the same before the Assessing Officer. In spite of the same, the Assessing Officer completed the assessment which is contrary to the law and facts on file and deserves to be quashed - Decided in favour of assessee.
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