Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
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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