Tribunal admitted the additional ground on jurisdiction. The Tribunal held that the assessee is  a non-resident Indian according to his permanent account number profile. The Assessing Officer, not knowing the status of the assessee, had assumed jurisdiction.  The faceless assessing unit had made a request to transfer the case from them because it was the case of a non-resident individual, who could be assessed only at the international charge. As a result, the ITO at Ajmer had no jurisdiction to issue the notice under section 148. Accordingly the notice and the consequential assessment order is quashed. (AY.2018-19)