Notice by an AO not having jurisdiction over the assessee is irrelevant. If the proper AO does not issue the notice within the time limit, the assessment is null and void. The argument that the non-jurisdictional AO issued the s. 143(2) notice as per PAN or computerized system or internal procedure is not relevant as it violates the law ( AY.2006-07)
ITO v. NVS Builders Pvt. Ltd.( 2018) 169 ITD 679(Delhi)(Trib) , www.itatonline.org
S. 143(2): Assessment – Notice by an AO not having jurisdiction over the assessee is irrelevant- Assessment was held to be bad in law .