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"21. Our attention was drawn to Parashuram Pottery Works Co. Ltd. V. ITO,
Circle I, Ward A, Rajkot, (1977) 106 ITR 1 (SC) which records that the
Assessing Officer entrusted with the task of calculating and realizing tax
should familiarize themselves with the relevant provisions and become well
versed with the law on the subject. This is a salutary advice. Indeed, there
have been lapses and faults resulting in the present litigation. Notice under
Section 147/148 of the Act was issued at the end of the limitation period.
Noticeably, Assessment Order for the assessment year 2013-2014 was
passed on 31.03.20I6, one year earlier. Second lapse is also apparent. Despite
correctly noting the background, notice under Section 147/148 of the Act
was not addressed in the correct name and even the PAN Number mentioned
was incorrect. Nevertheless, human errors and mistakes cannot and should
not nullify proceedings which are otherwise valid and no prejudice had been
caused. This is the effect and mandate of Section 292B of the Act."