https://www.taxtmi.com/caselaws?id=760249 ITAT Raipur held that assessment order u/s 143(3) was invalid due to jurisdictional defects. The initial notice u/s 143(2) was issued by ITO Ward-1(1) who lacked jurisdiction over corporate assessee with declared loss exceeding Rs. 15 lakh, which fell under ACIT/DCIT jurisdiction per CBDT instructions. The subsequent notice by jurisdictional ACIT-4(1) was issued beyond prescribed time limit of 30.09.2016. Following precedent in Durga Manikanta case, tribunal ruled that objection to assumption of jurisdiction in contravention of CBDT instructions differs from territorial jurisdiction objection under Section 124(3). Assessment order dated 20.12.2017 was struck down as unsustainable. Assessee's appeal was allowed. en-us Wed, 24 Jan 2024 00:00:00 +0530 Tue, 15 Oct 2024 15:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760249 ITAT Raipur held that assessment order u/s 143(3) was invalid due to jurisdictional defects. The initial notice u/s 143(2) was issued by ITO Ward-1(1) who lacked jurisdiction over corporate assessee with declared loss exceeding Rs. 15 lakh, which fell under ACIT/DCIT jurisdiction per CBDT instructions. The subsequent notice by jurisdictional ACIT-4(1) was issued beyond prescribed time limit of 30.09.2016. Following precedent in Durga Manikanta case, tribunal ruled that objection to assumption of jurisdiction in contravention of CBDT instructions differs from territorial jurisdiction objection under Section 124(3). Assessment order dated 20.12.2017 was struck down as unsustainable. Assessee's appeal was allowed. Case-Laws Income Tax Wed, 24 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760249