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The HC held that the Assessing Officer (AO) lacked jurisdiction to reopen an assessment order dated 19.12.2018 by invoking Section 154 of the Act of 1961 after the matter had been conclusively adjudicated by the designated authority under the DTVSV Act 2020, which issued a certificate of closure on 05.11.2021. Section 154 permits rectification of mistakes in orders passed by the AO but does not empower the AO to invalidate or override the final declaration issued by the designated authority under Section 5 of the DTVSV Act. The court emphasized that the AO cannot unsettle or render redundant the designated authority's order through a purported rectification. The Revisional Authority's endorsement of the AO's reopening was also set aside for failure to appreciate this legal position. Consequently, the reopening of the assessment was quashed, affirming the finality of the designated authority's certificate.
The HC held that the Assessing Officer (AO) lacked jurisdiction to reopen an assessment order dated 19.12.2018 by invoking Section 154 of the Act of 1961 after the matter had been conclusively adjudicated by the designated authority under the DTVSV Act 2020, which issued a certificate of closure on 05.11.2021. Section 154 permits rectification of mistakes in orders passed by the AO but does not empower the AO to invalidate or override the final declaration issued by the designated authority under Section 5 of the DTVSV Act. The court emphasized that the AO cannot unsettle or render redundant the designated authority's order through a purported rectification. The Revisional Authority's endorsement of the AO's reopening was also set aside for failure to appreciate this legal position. Consequently, the reopening of the assessment was quashed, affirming the finality of the designated authority's certificate.
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