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    <title>2012 (9) TMI 471 - ITAT, DELHI</title>
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    <description>A reassessment notice issued under section 148 by an officer lacking territorial jurisdiction over the assessee is invalid, because the belief that income has escaped assessment must be formed and acted on by the jurisdictional Assessing Officer who records the requisite reasons under section 147. Where the assessee&#039;s jurisdiction lay elsewhere and no fresh notice was issued by the proper officer, the reassessment could not be sustained. The defect was not cured by section 124(3)(b), since the objection was raised before completion of assessment and valid service was not shown, and section 292BB could not validate a notice issued without jurisdiction.</description>
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    <pubDate>Fri, 06 Jul 2012 00:00:00 +0530</pubDate>
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      <title>2012 (9) TMI 471 - ITAT, DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=216663</link>
      <description>A reassessment notice issued under section 148 by an officer lacking territorial jurisdiction over the assessee is invalid, because the belief that income has escaped assessment must be formed and acted on by the jurisdictional Assessing Officer who records the requisite reasons under section 147. Where the assessee&#039;s jurisdiction lay elsewhere and no fresh notice was issued by the proper officer, the reassessment could not be sustained. The defect was not cured by section 124(3)(b), since the objection was raised before completion of assessment and valid service was not shown, and section 292BB could not validate a notice issued without jurisdiction.</description>
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      <pubDate>Fri, 06 Jul 2012 00:00:00 +0530</pubDate>
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