ITAT allowed the assessee's appeal and quashed the CIT's order...

ITAT allowed the assessee's appeal and quashed the CIT's order under section 263. The Tribunal held that, in view of Explanation-D treating declared loss as "income" for jurisdictional purposes, the DCIT, Circle Mandi - which issued the section 143(2) notice - had jurisdiction; transfer of jurisdiction to the ITO, Kullu rendered the subsequent assessment order void for want of jurisdiction. Because the CIT's purported revision under section 263 lacked any legal foundation arising from an absence of jurisdiction, the revisional proceedings could not be sustained and the section 263 order was set aside.

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