I am seeking your expert advice and opinions regarding a peculiar jurisdictional dispute involving an automated backend PAN transfer and subsequent reassessment notices issued under Section 147 / 143(2). The details of the timeline and facts are as follows:
  1. Show-Cause Notice u/s 243: On 3rd June, the Delhi Income Tax office issued a show-cause notice proposing to transfer my jurisdiction to Bangalore, giving an objection deadline of 8th June.
  2. Objection Filed: On 7th June (well before the deadline), I formally filed my written objections against the proposed transfer on the e-filing portal.
  3. Defective Transfer Order: On 9th June, the Delhi authority passed a Section 243 transfer order, completely ignoring my objection on file and incorrectly citing "non-response" from the assessee. My PAN was subsequently migrated to Bangalore on the database.
  4. Grievance & Rejection by Destination AO: I immediately filed a portal grievance. Concurrently, the Bangalore AO rejected/declined the transfer, explicitly replying via email that they lack functional jurisdiction since they only handle corporate charges, whereas I am a salaried individual.
  5. Backend Software Pull-back: Following this impasse between the two charges, no fresh, reciprocal statutory order under Section 127/243 or CBDT directive was communicated to me. Instead, on 15th June, my PAN was internally routed back to the Delhi office via an administrative backend ITBA system modification (substantiated by full-system screenshots with timestamps).
  6. Reassessment Notices Issued: On 21st June, the Delhi Assessing Officer [Ward 34(5)] issued notices under Section 148 (for AY 2024-25) 
My Queries for the Forum:
  • Does Delhi legally possess territorial jurisdiction? Can an administrative backend software routing modification on the ITBA system validly vest or restore jurisdiction to the Delhi AO after a formal Section 243 transfer order failed/was rejected? Or does it create a total lack of jurisdiction (void ab initio)?
  • Impact of Section 124(3) and 292BB: If I do not challenge this at the threshold stage and file the prescribed return under Section 148, can the department successfully argue "deemed waiver" under Section 292BB or a missed 30-day window under Section 124(3) when the case eventually reaches the ITAT?
  • The "Void vs. Existing" Jurisdiction Contradiction: Can the department legally claim that because the original June 9 transfer order was procedurally defective (violating natural justice by suppressing my objection), the transfer was a nullity and therefore jurisdiction never legally left Delhi? Or does the Docrtine of Functus Officio apply to the Delhi AO once the order was signed?
I would highly appreciate your insights, relevant judicial precedents, and tactical recommendations on how to handle the upcoming response deadline.
 
Thank you in advance!