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, for assessment year 2016-17 issued by the
Patna High Court CWJC No.587 of 2022 dt.22-04-2025
Assistant Commissioner of Income Tax, Circle – 4, Patna
(Respondent No. 1) herein and also referred to as the
“Assessing Officer” hereinafter) initiating proceedings
for reassessment against the Petitioner as being wholly
illegal and without jurisdiction as the same has been
initiated on mere change of opinion.
ii) For issuance of an appropriate writ
quashing the preliminary order dated 21.12.2021
whereby the petitioner’s objection dated 02.12.2021 on
the issue of assumption of jurisdiction has been rejected
by National Faceless Assessment Centre, Delhi (also
referred to as the “NFAC” hereinafter) without having
jurisdiction over the petitioner’s case and in utter
violation of Principles of Natural Justice that too by a
non-speaking and cryptic order passed only as a formal
observance of the procedure laid down by the Hon’ble
Supreme Court in the case of GKN Driveshafts (India) vs.
ITO and Others reporeted in (2003) 259 ITR 19.
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