Section 148: Reason for Issue of Notice can be claimed before Filing of Return
CA Paras Dawar
Assessee Can Claim Reasons For Issue Of Notice U/S 148 Before Filing Of Return U/S 148.
Section 148 of the Income Tax Act, 1961 is possibly the most belligerent combat tank in the armory of Income Tax Department. This tank has been further strengthened by recent amendments by Finance Act 2012 which gives department power to issue notice u/s 148 where not more than sixteen years have elapsed from the end of the relevant assessment years, if there is any income in relation to any asset (including financial interest in any entity) located outside India, chargeable to tax, which has escaped assessment.
However, judiciary of the country has ensured that this tank is not misused to harass assessees, where there lies no reason that may cause an assessing officer to believe that income has escaped assessment.
Hon'ble Supreme Court in GKN Driveshafts (India) Ltd. vs. ITO & Ors. (2003) 259 ITR 19 (SC) had held that :-
"When a notice under section 148 of the Income-tax Act, 1961, is issued, the proper course of action for the notice is to file the return and, if he so desires, to seek reasons for issuing the notices. The assessing officer is bound to furnish reasons within a reasonable time. On receipt of reasons, the notice is entitled to file objections to issuance of notice and the assessing officer is bound to dispose of the same by passing a speaking order."
A point has always been bone of contention between department and representatives whether reasons for issue of notice u/s 148 can be issued prior to filing of return of income. Or to be more specific, are reasons required to be sent along with notice u/s 148.
So far as Section 148(2) of the Act is concerned, it is silent regarding 'communication of reasons' and as to whether the same are to be communicated before or after filing of return.
Allahabad High Court, while addressing this issue in the case of Mithilesh Kumar Tripathi vs CIT 2006) 280 ITR 16 (All.) held that :
- Normally one expects 'Reasons' to be communicated along with notice so that assessee is informed of the 'ground' for initiating reassessment in order to ensure that action is not 'arbitrary'. It shall enable an 'assessee' to take care of the 'escaped assessment' (which is the basis/foundation of the notice) as well as to take care, while filing fresh return, to disclose/ explain any other income, if any, which may have otherwise escaped assessment.
- Notice Under Section 148(2) of the Act requiring an assessee to file 'Revised-Return' for re-assessment without disclosing ground/'reasons' is no notice of the case to be met or opportunity to explain. Such a notice for sure lacks basic information and thus for certain fails to apprise the party even the basic ground/circumstance on the basis of which he is compelled by Assessing Officer to file revised return. It is complete denial of opportunity to defend and answer the Notice. Assessee is left in dark and compelled to make a 'roving and fishing search' to detect/locate alleged "escaped income". In case reason/ground is disclosed along with the notice (without disclosing 'source of information' or 'other material') it will definitely facilitate expeditious filing of revised return and also enable the 'Assessee' to declare, apart from the 'escaped income' pointed out in the notice, other 'escaped income' or 'undisclosed income'.
- In our considered opinion, if reasons are supplied along with notice under Section 148(2) of the Act, it shall obviate unnecessary, harassment to the assessee as well to the Revenue by avoiding unnecessary litigation which will save Courts also from being involved in unproductive litigations. Above all it shall be in consonance with the principles of natural justice, as discussed above.
Haj and Mansarovar pilgrimage gets Service Tax exemption
The Government exempts vide Notification No.17/2014 – Service Tax dated 20.08.2014 Services by Kumaon Mandal Vikas Nigam Limited and the Haj Committee in respect of a religious pilgrimage facilitated by the Ministry of External Affairs of the Government of India, under bilateral arrangement.
Notification No.17/2014 – Service Tax
New Delhi, the 20th August, 2014
G.S.R….(E).– In exercise of the powers conferred by sub-section (1) of section 93 of the Finance Act, 1994 (32 of 1994), the Central Government, being satisfied that it is necessary in the public interest so to do, hereby makes the following further amendments in the notification of the Government of India in the Ministry of Finance (Department of Revenue) No.25/2012-Service Tax, dated the 20th June, 2012, published in the Gazette of India, Extraordinary, Part II, Section 3, Sub-section (i) vide number G.S.R. 467 (E), dated the 20th June, 2012, namely:-
In the said notification,–
(i) in the opening paragraph, after entry 5,the following entry shall be inserted, namely:-
"5A. Services by a specified organisation in respect of a religious pilgrimage facilitated by the Ministry of External Affairs of the Government of India, under bilateral arrangement;";
(ii) in paragraph 2 relating to definitions, after clause (zf),the following clause shall be inserted, namely:-
'(zfa) "specified organisation" shall mean,-
(a) Kumaon Mandal Vikas Nigam Limited, a Government of Uttarakhand Undertaking; or
(b) 'Committee' or 'State Committee' as defined in section 2 of the Haj Committee Act, 2002 (35 of 2002);'.
[F. No.B1/1/2014 -TRU]
(Akshay Joshi)
Under Secretary to the Government of India
Note.- The principal notification was published in the Gazette of India, Extraordinary, vide notification No. 25/2012 – Service Tax, dated the 20th June, 2012, vide number G.S.R. 467 (E), dated the 20th June, 2012 and last amended vide notification No.06/2014 – Service Tax, dated the 11th July, 2014 vide number G.S.R. 475 (E), dated the 11th July, 2014
CPC (TDS) – How to close Short Payment Defaults using Online Correction facility
CPC (TDS) -Advisory for closure of Short Payment Defaults using Online Correction facility before allowing Conso Files
As you may be aware that at the time of filing TDS statements, it is mandatory to quote the challan particulars through which TDS payments have been made. The TDS forms prescribe quoting of such challans and the underlying deductee transactions corresponding to such challans.
However, it is observed that:
- At times, data entry mistakes are committed, while reporting tax payments in the respective TDS statements.
- Though CPC (TDS) makes best efforts to match such challans, however, they may remain unmatched leading to "Short Payment" demand.
- The above results into issuance of notices by the field officers.
To make the resolution process non-intrusive, CPC (TDS) proposes a new change while submitting request for download of the Consolidated (Conso) file for a particular quarter. If there is a "Short Payment defaults" on account of unmatched challans for the relevant quarter, the deductor would be provided with online view of all available unconsumed challans, which can be tagged with deductees, to close the above default.
Following are key information to be noted in this regard:
- CPC(TDS) mandates to close the above default by tagging unconsumed challans, if available in CPC(TDS) system, through online correction (without digital signature).
- In case there is no available challan for consumption, the deductor is required to first deposit the due tax in the bank and then the same challan will be available for tagging in CPC(TDS) system after around 3-4 days of deposit.
- The Online Correction facility of TRACES needs to be used for closure of the Short Payment default.
- The user will not be able to download Conso file for the relevant TDS statement on closure of the above default.
- Once the challan is suitably tagged, CPC(TDS) shall suo moto reprocess the cases thereby reducing the Short Payment default by equivalent amount.
What Actions to be taken:
- During submission of request for Conso File, a message will be displayed, if there are Short Payment defaults in the TDS statement and instructions will be provided to submit Online Correction.
- Details of defaults will be provided during Online Correction process.
- In case of insufficient challans, please use Challan ITNS 281 to pay the demand or use any other Challan, which has adequate balance available.
- Submit an Online Correction using the functionality on TRACES to tag the challans with deductee rows. Login to TRACES and navigate to "Defaults" tab to locate "Request for Correction" from the drop-down list.
Online Challan Corrections:
- A list of all Matched and Unmatched challans can be viewed by clicking the appropriate tab.
- Unmatched challans can be corrected and tagged to Deductee rows in the statement.
- The corrections in TDS statements can be raised even without Digital Signature.
- Correct KYC information needs to be submitted for the purpose of validation.
- All previous corrections pertaining to the statement should have been processed and the processing status can be verified from the Dashboard.
COMPANY CASES
Banking company --Board of directors--Shareholder-director--Nomination committee--Election of director by shareholders of bank other than Central Government--Rejection of nomination on ground that candidate over age and was nominated twice as officer-director of bank for over six years--Right to contest election in capacity of shareholder-director emanating from provisions of 1970 Act cannot be curtailed by reference to circulars which did not govern election of shareholder-director--Nomination committee acting arbitrarily and without authority in importing criteria not ex facie applicable to shareholders--Banking Companies (Acquisition and Transfer of Undertakings) Act, 1970, s. 9--Banking Regulation Act, 1949--Nationalised Banks (Management and Miscellaneous Provisions) Scheme, 1970--UCO Bank (Shares and Meetings) Regulations, 2003--Reserve Bank Guidelines dated 1-11-2007--Notifications dated 10-12-2007 and 13-10-2011-- Soumyendra Roy Choudhury v. UCO Bank (Cal) . . . 330
High Court --Powers--Temporary injunction--Court can issue temporary injunctions in mandatory form-- Soumyendra Roy Choudhury v. UCO Bank
(Cal) . . . 330
(Cal) . . . 330
Offences and prosecution --Offence by company--Failure by company to remit tax deducted at source--Criminal proceedings different from recovery proceedings--Pendency of recovery proceedings not bar to initiation of criminal proceedings--Sanction for prosecution--Effect of section 279--Sanction need not be issued only on instruction or direction of Chief Commissioner or Director-General--More than one person can be prosecuted as principal officer of company--Income-tax Act, 1961, ss. 2, 276B, 279-- Kingfisher Airlines Ltd. v. Assistant Commissioner of Income-tax
(Karn) . . . 374
(Karn) . . . 374
INCOME TAX REPORTS (ITR)--PRINT AND ONLINE EDITION
Appeal to High Court --Substantial question of law--Search and seizure--Block assessment--Undisclosed income--Excess stock of silver--Investment in excess stock of gold jewellery--Tribunal restricting additions based on material--Pure questions of fact--Income-tax Act, 1961, ss. 158BC, 260A-- CIT v. Mangal and Mangal (Mad) . . . 478
Assessment --Special audit--Condition precedent--Ledger account not containing narration--Whether charging of interest revenue neutral ascertainable only after all entries examined by special auditor--Failure to file details of expenditure in projects in special economic zone and other projects--Number of transactions between assessee and related parties--Condition as to nature and complexity of accounts satisfied--Direction for special audit warranted--Income-tax Act, 1961, s. 142(2A)-- DLF Ltd. v. Addl. CIT (Delhi) . . . 390
Business expenditure --Assessee entering into agreement to purchase furnace oil--Import without licence prohibited by law--Assessee transferring contractual liability to sister concern--Purchase of furnace oil and sale from sister concern in contravention of law--Amount paid as commission to sister concern--Not deductible--Income-tax Act, 1961, s. 37-- Overseas Trading and Shipping Co. P. Ltd. v. Asst. CIT (Guj) . . . 311
----Capital or revenue expenditure--Company jointly promoted by two companies--New company formed on bifurcation of business of such company--Amount paid for getting domestic customer data base--Amount paid for getting trained personnel--Revenue expenditure--Income-tax Act, 1961, s. 37-- CIT v. IBM Global Services India P. Ltd. (Karn) . . . 293
----Deduction only on actual payment--Disallowance--Contribution towards provident fund--Effect of sections 36 and 43B--Contribution of employer and employee made on or before due date for furnishing returns under section 139(1)--Entitled to deduction--Income-tax Act, 1961, ss. 2(24)(x), 36(1)(va), 43B-- Essae Teraoka P. Ltd. v. Deputy CIT (Karn) . . . 408
----Disallowance--Provision for gratuity--Effect of insertion of section 40A(7) w. e. f. 1-4-1973--Trust deed executed in December 1975 and granted approval in December 1975--Claim based on actuarial valuation--Assessee entitled to deduction of provision in assessment year 1973-74--Income-tax Act, 1961, s. 40A(7)-- CIT v. Maharaja Shree Umaid Mills Ltd. (Raj) . . . 341
----Sales promotion--Amount paid for sending a large consignment of mangoes to a person abroad--Claim that it was for purposes of business promotion--No evidence to support claim--Amount not deductible--Income-tax Act, 1961, s. 37-- Overseas Trading and Shipping Co. P. Ltd. v. Asst. CIT (Guj) . . . 311
Business loss --Loss on fluctuation in rate of foreign exchange--Deductible--Income-tax Act, 1961-- CIT v. IBM Global Services India P. Ltd. (Karn) . . . 293
Capital gains --Computation of capital gains--Capital asset having market value but cost of acquisition of which could not be ascertained--Cost to be taken at fair market value on statutorily specified date or at option of assessee market value on date of acquisition--Income-tax Act, 1961, ss. 45, 55-- Thakur Dwara Shri Krishanji Maharaj Handiyaya, Barnala v. CIT (P&H) . . . 381
----Exemption under sections 54 and 54F--Condition that on date of transfer assessee should not be in possession of residential house--â€Residential house†includes shared possession of a residential house--Co-owner not entitled to exemption--Income-tax Act, 1961, ss. 54, 54F-- CIT v. M. J. Siwani (Karn) . . . 356
Cash credit --Unexplained cash credits--Two-thirds of creditors unconfirmed--Books of account audited under section 44AB--Nothing to suggest in audit report that closing stock was on estimate basis and that sales suppressions introduced in names of sundry creditors--Unconfirmed sundry creditors treated as unexplained cash credit--Justified--Income-tax Act, 1961, s. 68-- R. C. Auto Centre (S. I.) v. ITO (Mad) . . . 305
Exemption --Educational institution--Application under section 10(23C)(vi) rejected on ground trust deed did not provide for distribution of funds on dissolution--Future contingency--Defect in trust deed rectified--Rejection of application not justified--Income-tax Act, 1961, s. 10(23C)-- St. Kabir Educational Society v. CBDT (P&H) . . . 378
----Infrastructure facility--Bank--Condition precedent--Pre-condition of notification in Official Gazette--Not applicable to bonds purchased by assessee during financial year 1997-98--Income-tax Act, 1961, s. 10(23G)-- CIT v. Lord Krishna Bank Ltd. (Bom) . . . 416
----Special allowance to meet expenses of office--Life Insurance Corporation of India--Conveyance and additional conveyance allowance for Development Officers fixed by formula--Exempt from tax--Income-tax Act, 1961, s. 10(14)-- CIT v. Madan Gopal Bansal (Raj) . . . 319
Reassessment --Notice--Condition precedent--Reason to believe income had escaped assessment--Reason must be based on relevant material--Notice for verifying evidence--Rejection of objection without speaking order--Notice and reassessment not valid--Income-tax Act, 1961, ss. 147, 148-- Mukesh Modi v. Deputy CIT (Raj) . . . 418
----Notice--Objections--Order passed on objections is part of process of determination--Not an order deciding disputes between parties--New contentions can be raised before Assessing Officer--Writ petition challenging order passed on objections not maintainable--Income-tax Act, 1961, ss. 147, 148-- Joint CIT v. Kalanithi Maran (Mad) . . . 453
Recovery of tax --Stay of recovery proceedings--Claim for exemption not proved--Recovery proceedings could not be stayed--Interim stay of fifty per cent. of tax during pendency of appeal--Income-tax Act, 1961-- Kanav Khanna v. CIT (P&H) . . . 386
Revision --Powers of Commissioner--Conditions precedent for exercise of powers--Order erroneous and prejudicial to Revenue--Satisfaction of Commissioner essential--Assessment order under section 143(3)--Assessing Officer having jurisdiction while issuing notice under section 143(3)--Subsequent loss of jurisdiction due to Departmental circular--Order of assessment not invalid--Revision of such order not justified--Income-tax Act, 1961, ss. 143, 263-- CIT v. Kailash Chand Methi (Raj) . . . 333
Search and seizure --Block assessment--Undisclosed income--Agricultural income--Agricultural income assessed in prior years--Amount of agricultural income not includible in undisclosed income--Income-tax Act, 1961-- CIT v. M. J. Siwani (Karn) . . . 356
----Block assessment--Undisclosed income--Amount shown as credit in the name of third person--Amount not disclosed in return--Amount assessable--Income-tax Act, 1961-- CIT v. M. J. Siwani (Karn) . . . 356
----Block assessment--Undisclosed income--Income shown in returns filed under section 139(1) or section 139(4) cannot be included--Income-tax Act, 1961, Ch. XIV-B-- CIT v. M. J. Siwani (Karn) . . . 356
----Jewellery discovered during search--Effect of CBDT Instruction--Jewellery within prescribed limits--Addition of value of part of jewellery as undisclosed income--Not justified--Instruction No. 1916 dated 11-5-1994--Income-tax Act, 1961-- CIT v. Satya Narain Patni (Raj) . . . 325
Valuation of stock --Land under litigation--Value to be determined with reference to purchase price and market value--Income-tax Act, 1961-- CIT v. M. J. Siwani (Karn) . . . 356
Writ --Existence of alternate remedy--Not an absolute bar on issue of writ--Constitution of India, art. 226-- Mukesh Modi v. Deputy CIT (Raj) . . . 418
----High Court--Reassessment--Alternative remedy--Challenge to order passed on objections of assessee--Writ petition not maintainable--Constitution of India, art. 226-- Joint CIT v. Kalanithi Maran (Mad) . . . 453
Art. 226 --Writ--Existence of alternate remedy--Not an absolute bar on issue of writ-- Mukesh Modi v. Deputy CIT (Raj) . . . 418
----Writ--High Court--Reassessment--Alternative remedy--Challenge to order passed on objections of assessee--Writ petition not maintainable-- Joint CIT v. Kalanithi Maran (Mad) . . . 453
S. 2(24)(x) --Business expenditure--Deduction only on actual payment--Disallowance--Contribution towards provident fund--Effect of sections 36 and 43B--Contribution of employer and employee made on or before due date for furnishing returns under section 139(1)--Entitled to deduction-- Essae Teraoka P. Ltd. v. Deputy CIT (Karn) . . . 408
S. 10(14) --Exemption--Special allowance to meet expenses of office--Life Insurance Corporation of India--Conveyance and additional conveyance allowance for Development Officers fixed by formula--Exempt from tax-- CIT v. Madan Gopal Bansal (Raj) . . . 319
S. 10(23C) --Exemption--Educational institution--Application under section 10(23C)(vi) rejected on ground trust deed did not provide for distribution of funds on dissolution--Future contingency--Defect in trust deed rectified--Rejection of application not justified-- St. Kabir Educational Society v. CBDT (P&H) . . . 378
S. 10(23G) --Exemption--Infrastructure facility--Bank--Condition precedent--Pre-condition of notification in Official Gazette--Not applicable to bonds purchased by assessee during financial year 1997-98-- CIT v. Lord Krishna Bank Ltd. (Bom) . . . 416
S. 36(1)(va) --Business expenditure--Deduction only on actual payment--Disallowance--Contribution towards provident fund--Effect of sections 36 and 43B--Contribution of employer and employee made on or before due date for furnishing returns under section 139(1)--Entitled to deduction-- Essae Teraoka P. Ltd. v. Deputy CIT (Karn) . . . 408
S. 37 --Business expenditure--Assessee entering into agreement to purchase furnace oil--Import without licence prohibited by law--Assessee transferring contractual liability to sister concern--Purchase of furnace oil and sale from sister concern in contravention of law--Amount paid as commission to sister concern--Not deductible-- Overseas Trading and Shipping Co. P. Ltd. v. Asst. CIT (Guj) . . . 311
----Business expenditure--Capital or revenue expenditure--Company jointly promoted by two companies--New company formed on bifurcation of business of such company--Amount paid for getting domestic customer data base--Amount paid for getting trained personnel--Revenue expenditure-- CIT v. IBM Global Services India P. Ltd. (Karn) . . . 293
----Business expenditure--Sales promotion--Amount paid for sending a large consignment of mangoes to a person abroad--Claim that it was for purposes of business promotion--No evidence to support claim--Amount not deductible-- Overseas Trading and Shipping Co. P. Ltd. v. Asst. CIT (Guj) . . . 311
S. 40A(7) --Business expenditure--Disallowance--Provision for gratuity--Effect of insertion of section 40A(7) w. e. f. 1-4-1973--Trust deed executed in December 1975 and granted approval in December 1975--Claim based on actuarial valuation--Assessee entitled to deduction of provision in assessment year 1973-74-- CIT v. Maharaja Shree Umaid Mills Ltd. (Raj) . . . 341
S. 43B --Business expenditure--Deduction only on actual payment--Disallowance--Contribution towards provident fund--Effect of sections 36 and 43B--Contribution of employer and employee made on or before due date for furnishing returns under section 139(1)--Entitled to deduction-- Essae Teraoka P. Ltd. v. Deputy CIT (Karn) . . . 408
S. 45 --Capital gains--Computation of capital gains--Capital asset having market value but cost of acquisition of which could not be ascertained--Cost to be taken at fair market value on statutorily specified date or at option of assessee market value on date of acquisition-- Thakur Dwara Shri Krishanji Maharaj Handiyaya, Barnala v. CIT (P&H) . . . 381
S. 54 --Capital gains--Exemption under sections 54 and 54F--Condition that on date of transfer assessee should not be in possession of residential house--â€Residential house†includes shared possession of a residential house--Co-owner not entitled to exemption-- CIT v. M. J. Siwani (Karn) . . . 356
S. 54F --Capital gains--Exemption under sections 54 and 54F--Condition that on date of transfer assessee should not be in possession of residential house--â€Residential house†includes shared possession of a residential house--Co-owner not entitled to exemption-- CIT v. M. J. Siwani (Karn) . . . 356
S. 55 --Capital gains--Computation of capital gains--Capital asset having market value but cost of acquisition of which could not be ascertained--Cost to be taken at fair market value on statutorily specified date or at option of assessee market value on date of acquisition-- Thakur Dwara Shri Krishanji Maharaj Handiyaya, Barnala v. CIT (P&H) . . . 381
S. 68 --Cash credit--Unexplained cash credits--Two-thirds of creditors unconfirmed--Books of account audited under section 44AB--Nothing to suggest in audit report that closing stock was on estimate basis and that sales suppressions introduced in names of sundry creditors--Unconfirmed sundry creditors treated as unexplained cash credit--Justified-- R. C. Auto Centre (S. I.) v. ITO (Mad) . . . 305
S. 142(2A) --Assessment--Special audit--Condition precedent--Ledger account not containing narration--Whether charging of interest revenue neutral ascertainable only after all entries examined by special auditor--Failure to file details of expenditure in projects in special economic zone and other projects--Number of transactions between assessee and related parties--Condition as to nature and complexity of accounts satisfied--Direction for special audit warranted-- DLF Ltd. v. Addl. CIT (Delhi) . . . 390
S. 143 --Revision--Powers of Commissioner--Conditions precedent for exercise of powers--Order erroneous and prejudicial to Revenue--Satisfaction of Commissioner essential--Assessment order under section 143(3)--Assessing Officer having jurisdiction while issuing notice under section 143(3)--Subsequent loss of jurisdiction due to Departmental circular--Order of assessment not invalid--Revision of such order not justified-- CIT v. Kailash Chand Methi (Raj) . . . 333
S. 147 --Reassessment--Notice--Condition precedent--Reason to believe income had escaped assessment--Reason must be based on relevant material--Notice for verifying evidence--Rejection of objection without speaking order--Notice and reassessment not valid-- Mukesh Modi v. Deputy CIT (Raj) . . . 418
----Reassessment--Notice--Objections--Order passed on objections is part of process of determination--Not an order deciding disputes between parties--New contentions can be raised before Assessing Officer--Writ petition challenging order passed on objections not maintainable-- Joint CIT v. Kalanithi Maran (Mad) . . . 453
S. 148 --Reassessment--Notice--Condition precedent--Reason to believe income had escaped assessment--Reason must be based on relevant material--Notice for verifying evidence--Rejection of objection without speaking order--Notice and reassessment not valid-- Mukesh Modi v. Deputy CIT (Raj) . . . 418
----Reassessment--Notice--Objections--Order passed on objections is part of process of determination--Not an order deciding disputes between parties--New contentions can be raised before Assessing Officer--Writ petition challenging order passed on objections not maintainable-- Joint CIT v. Kalanithi Maran (Mad) . . . 453
Ch. XIV-B --Search and seizure--Block assessment--Undisclosed income--Income shown in returns filed under section 139(1) or section 139(4) cannot be included-- CIT v. M. J. Siwani (Karn) . . . 356
S. 158BC --Appeal to High Court--Substantial question of law--Search and seizure--Block assessment--Undisclosed income--Excess stock of silver--Investment in excess stock of gold jewellery--Tribunal restricting additions based on material--Pure questions of fact-- CIT v. Mangal and Mangal (Mad) . . . 478
S. 260A --Appeal to High Court--Substantial question of law--Search and seizure--Block assessment--Undisclosed income--Excess stock of silver--Investment in excess stock of gold jewellery--Tribunal restricting additions based on material--Pure questions of fact-- CIT v. Mangal and Mangal (Mad) . . . 478
S. 263 --Revision--Powers of Commissioner--Conditions precedent for exercise of powers--Order erroneous and prejudicial to Revenue--Satisfaction of Commissioner essential--Assessment order under section 143(3)--Assessing Officer having jurisdiction while issuing notice under section 143(3)--Subsequent loss of jurisdiction due to Departmental circular--Order of assessment not invalid--Revision of such order not justified-- CIT v. Kailash Chand Methi (Raj) . . . 333
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