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    <title>2023 (3) TMI 1240 - ITAT RAIPUR</title>
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    <description>A reassessment notice issued under section 148 by an officer who did not then have jurisdiction was held void ab initio, because the relevant jurisdiction had already vested in another assessing unit under the applicable notification. A later transfer of the case did not cure the defect, as the notice was non est when issued and the reopening was invalid at inception. The challenge was treated as one of inherent jurisdiction rather than mere territorial jurisdiction, so the limitation under section 124(3) did not bar it. The consequential assessment, resting on an invalid assumption of jurisdiction, was therefore quashed in favour of the assessee.</description>
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    <pubDate>Mon, 27 Mar 2023 00:00:00 +0530</pubDate>
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      <title>2023 (3) TMI 1240 - ITAT RAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=435854</link>
      <description>A reassessment notice issued under section 148 by an officer who did not then have jurisdiction was held void ab initio, because the relevant jurisdiction had already vested in another assessing unit under the applicable notification. A later transfer of the case did not cure the defect, as the notice was non est when issued and the reopening was invalid at inception. The challenge was treated as one of inherent jurisdiction rather than mere territorial jurisdiction, so the limitation under section 124(3) did not bar it. The consequential assessment, resting on an invalid assumption of jurisdiction, was therefore quashed in favour of the assessee.</description>
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      <pubDate>Mon, 27 Mar 2023 00:00:00 +0530</pubDate>
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