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The sum and substance of the grievance of the assessee is that the Commissioner of Income-tax (Appeals) erred in confirming the assessment by rejecting the contention of the assessee that the notice issued under section 148 of the Income-tax Act, 1961and proceedings in consequence thereto, are bad in law in the absence of reasons recorded by the Assessing Officer having jurisdiction over the case of the assessee. In the result, the appeal filed by the assessee is allowed.

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Section 147&148 of the Income Tax Act, 1961 — Reassessment — Where notice issued under section 148 was issued by one AO for the A.Y. 2009-10 and the assessment was framed by a different AO whereas the jurisdiction of the assessee was with another AO the assessment order framed under section 143 read with section 147 was bad in law—Smt. Usha Singhal vs. Income tax Officer [2019] 74 ITR (trib) 535 (Delhi)

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