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The ITAT held that the assumption of jurisdiction by the Range head (Addl. CIT, Range-1, Raipur) to perform Assessing Officer functions under section 2(7A) without an order under section 120(4)(b) was invalid. The tribunal found no legal basis for the range head's jurisdiction, referencing the Jindal Power Ltd. case. The revenue's reliance on CBDT instructions and Notification No. 6/2009 was rejected as insufficient to confer legitimate jurisdictional authority. Consequently, the assessment order dated 03.02.2014 framed under section 144 was quashed due to lack of inherent jurisdictional competence.
The ITAT held that the assumption of jurisdiction by the Range head (Addl. CIT, Range-1, Raipur) to perform Assessing Officer functions under section 2(7A) without an order under section 120(4)(b) was invalid. The tribunal found no legal basis for the range head's jurisdiction, referencing the Jindal Power Ltd. case. The revenue's reliance on CBDT instructions and Notification No. 6/2009 was rejected as insufficient to confer legitimate jurisdictional authority. Consequently, the assessment order dated 03.02.2014 framed under section 144 was quashed due to lack of inherent jurisdictional competence.
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