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TMI Blog2022 (7) TMI 1311X X X X Extracts X X X X X X X X Extracts X X X X ..... ction? - HELD THAT:- Tribunal has found that the acknowledgment receipt of the return of income shows that the respondent assessee had been filing its returns since inception i.e. AY 2005-06 at the address mentioned at New Delhi. It is pertinent to mention that in the Assessment Year 2012-13 when the assessee s case was selected for scrutiny, the assessee had within a month filed its objection to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... This Court is of the view that the approach adopted by both the Assessing Officers i.e. ITO, Ward-10(2), Kolkata as well as PCIT, Kolkata was contrary to the mandate of law, in particular, Section 124(4) of the Act. - ITA 228/2022 - - - Dated:- 27-7-2022 - HON'BLE MR. JUSTICE MANMOHAN AND HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA Appellant Through: Mr. Puneet Rai and Ms. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessee had never raised any objection to the jurisdiction. 3. He submits that the ITAT also failed to appreciate that the assessee had not made any request for change of jurisdiction under Section 127 of the Income Tax Act, 1961 (for short Act ) between the Assessment Years 2006-07 and 2012-13. 4. However, a perusal of the paper book reveals that the Tribunal has found that the acknowle ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sment was made to the PCIT. However, in the present case, the Assessing Officer rejected the objection regarding the jurisdiction and referred the matter to the PCIT to decide the issue after sixteen months. Further, the PCIT instead of deciding the issue of jurisdiction ordered that the issue of transfer of the jurisdiction will be decided after the completion of assessment. 6. This Court is o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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