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Reopening of assessment was held invalid where the officer who...
Jurisdictional validity: notice issued by a non jurisdictional officer invalidates reassessment where no formal transfer or independent verification occurred.
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Reopening of assessment was held invalid where the officer who recorded satisfaction and issued the notice lacked jurisdiction and no formal transfer of jurisdiction was made; the reasons recorded omitted PAN and prior completion under section 143(3) and relied solely on Investigation Wing information without independent verification, rendering assumption of jurisdiction defective. Consequentially reassessment proceedings and the assessment order were quashed as the notice issued by a non jurisdictional officer did not confer valid authority to reopen the completed assessment.
Reopening of assessment was held invalid where the officer who recorded satisfaction and issued the notice lacked jurisdiction and no formal transfer of jurisdiction was made; the reasons recorded omitted PAN and prior completion under section 143(3) and relied solely on Investigation Wing information without independent verification, rendering assumption of jurisdiction defective. Consequentially reassessment proceedings and the assessment order were quashed as the notice issued by a non jurisdictional officer did not confer valid authority to reopen the completed assessment.
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