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    <title>2025 (5) TMI 95 - ITAT RAIPUR</title>
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    <description>An assessment made by an Additional Commissioner was held invalid because no order under section 120(4)(b) had empowered him to act as the Assessing Officer, and no transfer order under section 127 had been passed. CBDT Instruction No. 6/2009 could not substitute for the missing statutory authorisation, as it was only administrative guidance. The objection to jurisdiction was not barred by section 124(3), because that provision concerns territorial jurisdiction, whereas the challenge went to inherent jurisdiction and the very authority to complete the assessment. The jurisdictional objection was therefore upheld and the assessment was void.</description>
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    <pubDate>Thu, 30 Jan 2025 00:00:00 +0530</pubDate>
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      <title>2025 (5) TMI 95 - ITAT RAIPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=769823</link>
      <description>An assessment made by an Additional Commissioner was held invalid because no order under section 120(4)(b) had empowered him to act as the Assessing Officer, and no transfer order under section 127 had been passed. CBDT Instruction No. 6/2009 could not substitute for the missing statutory authorisation, as it was only administrative guidance. The objection to jurisdiction was not barred by section 124(3), because that provision concerns territorial jurisdiction, whereas the challenge went to inherent jurisdiction and the very authority to complete the assessment. The jurisdictional objection was therefore upheld and the assessment was void.</description>
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      <pubDate>Thu, 30 Jan 2025 00:00:00 +0530</pubDate>
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