2|Page
ITA No. 2099, 2100 & 2101/Del/2023
notices herein at pages 83, 88 and 59 of the paper-book compiled
assessment year-wise to this clinching effect. We accordingly quote
PCIT Vs. Gopal Kumar Goyal, 153 taxmann.com 534 (Del); PCIT
Vs. Sahara Life Insurance Co. Ltd., 432 ITR 82 (Del) and Mohd.
Farhan A. Shaikh v. ACIT ( 2021 ) 434 ITR 1 (Bom) (FB) to conclude
that such a failure at the learned Assessing Officer's behest in not
specifying the corresponding limb(s) in section 271(1)(c) show-
cause notice indeed vitiates the entire proceedings itself. We
accordingly uphold the learned CIT(A)'s action on this first and
foremost legal issue in assessee's favour and against the
department.
2|Page
ITA No. 2099, 2100 & 2101/Del/2023
notices herein at pages 83, 88 and 59 of the paper-book compiled
assessment year-wise to this clinching effect. We accordingly quote
PCIT Vs. Gopal Kumar Goyal, 153 taxmann.com 534 (Del); PCIT
Vs. Sahara Life Insurance Co. Ltd., 432 ITR 82 (Del) and Mohd.
Farhan A. Shaikh v. ACIT ( 2021 ) 434 ITR 1 (Bom) (FB) to conclude
that such a failure at the learned Assessing Officer's behest in not
specifying the corresponding limb(s) in section 271(1)(c) show-
cause notice indeed vitiates the entire proceedings itself. We
accordingly uphold the learned CIT(A)'s action on this first and
foremost legal issue in assessee's favour and against the
department.
2|Page
ITA No. 2099, 2100 & 2101/Del/2023
notices herein at pages 83, 88 and 59 of the paper-book compiled
assessment year-wise to this clinching effect. We accordingly quote
PCIT Vs. Gopal Kumar Goyal, 153 taxmann.com 534 (Del); PCIT
Vs. Sahara Life Insurance Co. Ltd., 432 ITR 82 (Del) and Mohd.
Farhan A. Shaikh v. ACIT ( 2021 ) 434 ITR 1 (Bom) (FB) to conclude
that such a failure at the learned Assessing Officer's behest in not
specifying the corresponding limb(s) in section 271(1)(c) show-
cause notice indeed vitiates the entire proceedings itself. We
accordingly uphold the learned CIT(A)'s action on this first and
foremost legal issue in assessee's favour and against the
department.