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In the result, appeals filed by the assessee are allowed
Bench: Shri Aby T. Varkey & Shri Amitabh Shukla
Charitable Trust :: 14 :: being F No.370153/7/2023 TPL which has been dealt with above. Therefore, no reliance can be placed on the said Office Memorandum to justify that the JAO has jurisdiction to issue notice under Section 148 of the Act. Further the Hon'ble Telangana High Court in the case of Kankanala Ravindra Reddy vs. Income Tax Officer14 has held