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    <title>Section 147 Reassessment Invalid When Initial Notice Issued by Officer Without Jurisdiction Over NRI Taxpayer</title>
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    <description>The ITAT ruled in favor of the non-resident Indian taxpayer, invalidating the reopening of assessment under section 147. The notice under section 148 was initially issued by ITO Ward-3(1), Chandigarh, who lacked jurisdiction over NRI assessees. Subsequently, DCIT, International Taxation assumed jurisdiction based on this invalid notice without issuing a fresh notice. The Tribunal noted that the taxpayer had resided in Afghanistan until returning to India under adverse circumstances, and emphasized that the ITO&#039;s unilateral transfer of the case to DCIT, International Taxation could not cure the jurisdictional defect. The proceedings were held bad in law due to the initial issuance by a non-jurisdictional authority.</description>
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    <pubDate>Fri, 28 Mar 2025 08:31:29 +0530</pubDate>
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      <title>Section 147 Reassessment Invalid When Initial Notice Issued by Officer Without Jurisdiction Over NRI Taxpayer</title>
      <link>https://www.taxtmi.com/highlights?id=86936</link>
      <description>The ITAT ruled in favor of the non-resident Indian taxpayer, invalidating the reopening of assessment under section 147. The notice under section 148 was initially issued by ITO Ward-3(1), Chandigarh, who lacked jurisdiction over NRI assessees. Subsequently, DCIT, International Taxation assumed jurisdiction based on this invalid notice without issuing a fresh notice. The Tribunal noted that the taxpayer had resided in Afghanistan until returning to India under adverse circumstances, and emphasized that the ITO&#039;s unilateral transfer of the case to DCIT, International Taxation could not cure the jurisdictional defect. The proceedings were held bad in law due to the initial issuance by a non-jurisdictional authority.</description>
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      <pubDate>Fri, 28 Mar 2025 08:31:29 +0530</pubDate>
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