None
RU
Reassessment notice u/s. 148 without DIN is invalid and non-est
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taxguruin
Thus, the legal ground raised by the assessee qua non-availability of DIN number upon notice u/s 148 dated 30/07/2022 stands allowed.
Held that notice u/s 148 issued on 31.03.2022 by the jurisdictional assessing officer is an invalid notice and same is therefore quashed.
It was argued that notice u/s 148 dated 30.07.2022 was followed by a letter of even date where it was stated that notice u/s 148 dated 30.07.2022 is deemed to be having DIN No.ITBA / AST / M / 148_1 / 2022-23 / 1044351961(1).
Thus, the legal ground raised by the assessee qua non-availability of DIN number upon notice u/s 148 dated 30/07/2022 stands allowed.
The Revenue had argued that both the Jurisdictional Assessing Officer (JAO) and the Faceless Assessing Officer (FAO) had concurrent jurisdiction in issuing such notices.
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