Held that the notice under section 148 of the Act was issued by the ITO, Phagwara, after recording reasons for initiating proceedings under section 147 of the Act, whereas the assessment order under section 144 read with section 147 was passed by the Dy. CIT (IT), Circle Chandigarh. Further, the competent authority had not passed any order under section 127(2) of the Act transferring the case from the ITO, Phagwara to the Dy. CIT (IT) Circle Chandigarh. The order passed by the Dy. CIT (IT), Circle Chandigarh under section 144 read with section 147 of the Act was liable to be quashed. (AY.2011-12)
Uttam Singh v. Dy. CIT(IT) (2021) 88 ITR (SN) 1 (Chd.)(Trib.)
S. 147 : Reassessment-Jurisdiction-Notice issued by one Officer-Reassessment order was passed by another circle-No order by Competent Authority transferring case-Order was liable to be quashed. [S. 127(2), 144, 148]