In the result, all the three appeals filed by the assessee are stands allowed for statistical purposes
Bench: Shri Sandeep Gosain & Shri Om Prakash Kant
section 142(1) of the Act through the automated allocation became operative only subsequently. 5. Accordingly, NFAC had no jurisdiction, authority or statutory mandate even to issue notice u/s. 142(1) prior to 30- 3-2022, and therefore the entire assessment proceedings initiated by such invalid notices and culminating in the assessment order dated 23-09-2021, are without authority