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The High Court upheld the validity of the Assessing Officer's jurisdiction to frame the assessment order u/s 144. Even if the case was not liable for compulsory scrutiny per CBDT guidelines, it fell within Section 143(2) allowing the AO to issue notice and proceed with assessment u/s 144 if income had escaped assessment. The AO's power u/s 143(2) is statutory and cannot be curtailed by CBDT instructions, as that would require the AO to dispose of a case in a manner not prescribed by statute. The ITAT order upholding the assessment u/s 144 was found to have no illegality or infirmity.
The High Court upheld the validity of the Assessing Officer's jurisdiction to frame the assessment order u/s 144. Even if the case was not liable for compulsory scrutiny per CBDT guidelines, it fell within Section 143(2) allowing the AO to issue notice and proceed with assessment u/s 144 if income had escaped assessment. The AO's power u/s 143(2) is statutory and cannot be curtailed by CBDT instructions, as that would require the AO to dispose of a case in a manner not prescribed by statute. The ITAT order upholding the assessment u/s 144 was found to have no illegality or infirmity.
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