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    <title>2022 (3) TMI 218 - ITAT MUMBAI</title>
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    <description>A pure legal objection to the validity of the assessment order could be raised as an additional ground at the appellate stage because it went to the root of jurisdiction and required no fresh evidence. The assessee&#039;s jurisdictional challenge was also accepted on merits: an Additional Commissioner could exercise Assessing Officer powers only if validly authorised under the statutory scheme, and the notifications relied on by the Revenue were found insufficient in the absence of a valid order under section 120(4)(b) of the Income-tax Act, 1961. The assessment order was therefore treated as without jurisdiction and void ab initio, with the assessee succeeding and the Revenue&#039;s connected appeals dismissed.</description>
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