Erroneous assessment as a jurisdictional defect undermines tax assessments made contrary to law and not mere valuation judgments.

Definitions from Black's Law Dictionary: Erroneous means involving error or deviation from law. An Erroneous assessment is an assessment deviating from law and thus invalid, constituting a jurisdictional defect rather than referring to the Assessing Officer's valuation judgment. An Erroneous judgment is a decision rendered in court practice but contrary to law due to a mistaken view or erroneous application of legal principles.

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