Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
After transfer of the assessee's jurisdiction from Ajmer to Mumbai under section 127, the earlier Assessing Officer became functus officio and lacked authority to issue the reassessment notice or complete assessment. The Tribunal held that valid assumption of jurisdiction is a condition precedent, not a procedural irregularity, so proceedings initiated by an officer without inherent jurisdiction are void ab initio. Accordingly, the reassessment orders for both years were quashed as invalid, and the Revenue's grounds on the merits became academic and infructuous.
After transfer of the assessee's jurisdiction from Ajmer to Mumbai under section 127, the earlier Assessing Officer became functus officio and lacked authority to issue the reassessment notice or complete assessment. The Tribunal held that valid assumption of jurisdiction is a condition precedent, not a procedural irregularity, so proceedings initiated by an officer without inherent jurisdiction are void ab initio. Accordingly, the reassessment orders for both years were quashed as invalid, and the Revenue's grounds on the merits became academic and infructuous.
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