Nabiul Industrial Metal P. Ltd. v. ITO (2024) 115 ITR 81(SN)(Kol)(Trib)

S. 144B : Faceless Assessment-Additional ground-Cash credits-Information from Investigation wing-Direction to give explanation before 29-3-2022-Assessment order assed without jurisdiction-Assessment order is invalid.[S. 68, 147, 148, 151A]

The assessee raised an additional ground that the National Faceless Assessment Centre had erred in assuming jurisdiction under section 151A read with section 144B since they were not empowered to make assessment in a faceless manner prior to March 29, 2022.  Tribunal held that the show-cause notice issued on March 28, 2022 was digitally signed showing the date of March 29, 2022 at 00:20:37 IST whereas the assessee is  directed to give explanation before March 29, 2022.  The Assessing Officer’s assumption of jurisdiction prior to March 29, 2022 is  without authority.(AY. 2017-18)

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