Can AO initiate proceedings u/s 148 of the IT Act once the proceedings u/s 147, 148, and 151 have been declared invalid?


Quick Summary
This Income Tax Appellate Tribunal case concerns whether an Assessing Officer (AO) can initiate new proceedings under Section 148 of the Income Tax Act after previous proceedings under Sections 147, 148, and 151 were found to be invalid. The CIT(A) had previously ruled the notice under Section 148 invalid due to invalid prior sanction but directed the AO to issue a fresh notice following the correct procedure. The assessee argued that if the initial proceedings were invalid, no new direction could be issued.

Court :
ITAT Delhi

Brief :
This appeal filed by the assessee for the assessment year 2011-12 is directed against the order of Ld. CIT(A)-14, New Delhi dated 28.10.2019. The assessee has raised following grounds of appeal:-

Citation :
ITA No.9687/Del/2019

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