When CIT( Administration) has given instruction to reopen the case by giving 148 notice, then what is the meaning of transfer of jurisdiction. My point is that whether any void assessment can be reopened or not. In my view once it is void means it can not be reassessed. Whether I am correct or not. If yes please give some case laws. thanks for answering
17 July 2011
as its time barred for 143(3) but CIT can not go against ITO directly, unless the assessee makes complain, so giving your plea that ITO is not aware of rules and makes crazy assessments, and request to make transfer of file to some other officer.
department will make reassessment for sure as order under 147 is issued and condemned again, so change of officer will make your side heavier, usually in such case AC will call the file to himself, and make a summery addition of few hundred rupees as additinal tax collected.