S S BRAHMA EDUCATIONAL TRUST,MAYURBHANJ vs. PRINICIPAL COMMISSIONER OF INCOME TAX, PCIT, SAMBALPUR, SAMBALPUR
In the result, appeal of the assessee is allowed
ITA 107/CTK/2024[2015-16]Status: HeardITAT Cuttack05 Jun 2024AY 2015-16
For Appellant: Shri P.K.Mishra, AdvocateFor Respondent: Shri Sanjay Kumar, CIT-DR
Section 148Section 263Section 69
548
(Bom) wherein it was held that assessee was entitled to challenge the jurisdiction of the AO to initiate re-assessment proceedings before the CIT(A) in the second round of proceedings, even though he had not raised it in earlier proceedings before the AO or in the earlier appeal.
8.10. Thus, on the basis of aforesaid discussion
