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    <title>2024 (8) TMI 1517 - ITAT DELHI</title>
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    <description>The ITAT Delhi held that a reassessment notice u/s 148 issued by ITO Ward 1(2)(5), Meerut was invalid due to lack of jurisdiction. The assessee had declared income above Rs. 15 lakhs, which per CBDT Instruction No. 01/2011 should be assessed by ACIT/DCIT in non-metro cities. The PAN was transferred to ACIT Circle 1(1)(1), Meerut only on 15.05.2024, but the notice was issued on 30.03.2021 by the non-jurisdictional ITO. The tribunal ruled jurisdiction cannot be waived or created by consent, and reassessment notices are jurisdictional matters, not procedural ones. The case was decided in favor of the assessee.</description>
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    <pubDate>Wed, 28 Aug 2024 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=460477</link>
      <description>The ITAT Delhi held that a reassessment notice u/s 148 issued by ITO Ward 1(2)(5), Meerut was invalid due to lack of jurisdiction. The assessee had declared income above Rs. 15 lakhs, which per CBDT Instruction No. 01/2011 should be assessed by ACIT/DCIT in non-metro cities. The PAN was transferred to ACIT Circle 1(1)(1), Meerut only on 15.05.2024, but the notice was issued on 30.03.2021 by the non-jurisdictional ITO. The tribunal ruled jurisdiction cannot be waived or created by consent, and reassessment notices are jurisdictional matters, not procedural ones. The case was decided in favor of the assessee.</description>
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      <pubDate>Wed, 28 Aug 2024 00:00:00 +0530</pubDate>
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