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As a necessary corollary it follows that no proceedings could have been taken under s. 147 of the Act in pursuance of such invalid notice.

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Section 147, 148 & 292B of the Income Tax Act, 1961 – Reassessment – While the reasons for reopening the assessment have been recorded by jurisdictional AO viz. Deputy Commissioner of income tax, Circle -2, Jamnagar, the impugned notice under section 148(1) has been issued by the ITO, Ward2(2), Jamnagar who had no jurisdiction over the assessee. Notice was invalid, hence, impugned notice under section 148(1) as well as all the proceedings taken pursuant thereto cannot be sustained — Pankajbhai Jaysukhlal Shah vs. Assistant Commissioner of income tax [2020] 312 CTR (Gujarat) 300

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