https://www.taxtmi.com/caselaws?id=458265 ITAT Mumbai held that reassessment notices u/s 148 issued by DCIT were invalid on jurisdictional grounds. For assessment years where corporate assessee's income was below Rs. 30 lakhs, CBDT Instruction No. 01/2011 mandated that only territorial ITO had jurisdiction, not DCIT. DCIT's assumption of jurisdiction violated Article 14 and Rule of Law principles. Additionally, reasons recorded for reopening were based on mere suspicion rather than belief of income escapement, constituting impermissible fishing inquiry. The tribunal quashed all reassessment proceedings, ruling in favor of the assessee on both jurisdictional and substantive grounds. en-us Mon, 27 Feb 2023 00:00:00 +0530 Thu, 17 Oct 2024 20:13:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=458265 ITAT Mumbai held that reassessment notices u/s 148 issued by DCIT were invalid on jurisdictional grounds. For assessment years where corporate assessee's income was below Rs. 30 lakhs, CBDT Instruction No. 01/2011 mandated that only territorial ITO had jurisdiction, not DCIT. DCIT's assumption of jurisdiction violated Article 14 and Rule of Law principles. Additionally, reasons recorded for reopening were based on mere suspicion rather than belief of income escapement, constituting impermissible fishing inquiry. The tribunal quashed all reassessment proceedings, ruling in favor of the assessee on both jurisdictional and substantive grounds. Case-Laws Income Tax Mon, 27 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=458265