S. 148 : Reassessment-Notice-Transfer of case-Case is transferred by Asstt. Commissioner, Moradabad to Dy. Director/Asstt. Director (Intl. Taxn.), Lucknow-No notice under section 127 was served on assessee before transferring jurisdiction-Fnal assessment order passed by Dy. Director/Asstt. Director (Intl. Taxn.), Lucknow-Without jurisdiction, non-est, illegal and bad in law-Reference to dispute resolution panel-Non eligible assessee-Draft order is not valid-Notice under section 148 was issued on 3-7-2019 and limitation would have been extended up to 30-9-2021-Assessment order passed on 28-6-2022, is barred by limitation provided under section 153(2) [S. 92CA(2), 127, 144C, 147, 153(2)]
Shyam Sunder Bhartia. v. DCIT (IT) (2023) 200 ITD 117 (Lucknow) (Trib.)