Jurisdictional competence in reassessment proceedings defeated where returned income fell below the prescribed monetary threshold.

Assessments framed in a second round of proceedings were held invalid because the returned income in the relevant years was below the jurisdictional monetary threshold under CBDT Circular No. 1/2011. The Tribunal found that the Assessing Officer lacked jurisdictional competence to complete the assessments, and a Revenue objection based on a later year did not cure that defect. As a result, the impugned assessments were quashed for want of jurisdiction, the assessee succeeded on the jurisdictional ground, and the merits became academic.

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Issues: Whether the second round assessments framed by the Assessing Officer were valid in law when the returned income was below the monetary threshold prescribed for jurisdiction under CBDT Circular No. 1/2011.

Analysis: The appeals arose from second round assessments made pursuant to remand directions. The assessee questioned the Assessing Officer's authority to complete the assessments, relying on the jurisdictional monetary limit. The returned income in the relevant assessment years was below the threshold, and the Revenue's objection based on a later year did not dislodge the jurisdictional defect. The Tribunal held that the Assessing Officer lacked jurisdiction to frame the impugned assessments in light of the applicable CBDT circular and the governing legal position on jurisdictional competence.

Conclusion: The impugned assessments were quashed for want of jurisdiction, and the assessee succeeded on the jurisdictional ground.

Final Conclusion: The appeals were allowed and the substantive issues on merits were rendered academic.

Ratio Decidendi: An assessment made by an officer lacking the prescribed jurisdictional competence is invalid and liable to be quashed, even in a second round of assessment proceedings.

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