https://www.taxtmi.com/caselaws?id=751021 The Bombay HC set aside reassessment proceedings initiated by an Assistant Commissioner who lacked jurisdiction over a non-resident assessee. The petitioner, filing returns as NRI for six years with residential status shown as non-resident in IT portal and intimations, challenged the Section 148A(b) notice. The AO admitted lack of jurisdiction but proceeded due to time constraints before limitation expired. The HC held that shortage of time cannot confer jurisdiction on a non-jurisdictional officer, declaring the notice invalid ab-initio. Transfer of proceedings cannot validate initially invalid actions. Petition allowed in assessee's favor. en-us Thu, 28 Mar 2024 00:00:00 +0530 Mon, 03 Mar 2025 15:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=751021 The Bombay HC set aside reassessment proceedings initiated by an Assistant Commissioner who lacked jurisdiction over a non-resident assessee. The petitioner, filing returns as NRI for six years with residential status shown as non-resident in IT portal and intimations, challenged the Section 148A(b) notice. The AO admitted lack of jurisdiction but proceeded due to time constraints before limitation expired. The HC held that shortage of time cannot confer jurisdiction on a non-jurisdictional officer, declaring the notice invalid ab-initio. Transfer of proceedings cannot validate initially invalid actions. Petition allowed in assessee's favor. Case-Laws Income Tax Thu, 28 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=751021