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2022 (6) TMI 131 - HC - Income TaxValidity of assessment u/s 147 read with Sections 144 & 144B - Petitioner states that notice has been issued by a non-jurisdictional assessing officer to a non-existent entity - HELD THAT:- A perusal of the paper book reveals that none of the aforesaid submissions and contentions have been considered by the AO - Since in the present case, the issue of jurisdiction is a mixed question of fact and law, this Court is of the view that it is necessary that the AO gives its opinion on the said issue. Accordingly, this Court sets aside the impugned assessment order and demand notice u/s 156. Assessing Officer is directed to consider the aforesaid submissions and contentions advanced by the parties as well as the reply dated 29th March, 2022 filed by the Petitioner and pass a fresh reasoned order in accordance with law within twelve weeks.
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