https://www.taxtmi.com/caselaws?id=461991 ITAT Kolkata held that reopening notice u/s 148 issued by non-jurisdictional AO rendered the assessment invalid. Following SC precedent in Hotel Blue Moon case, the tribunal ruled that jurisdictional AO issuing notice u/s 148 is sine qua non for valid reopening proceedings u/s 147. Since notice was issued by AO lacking jurisdiction over assessee, it was treated as non-est. Assessment framed u/s 143(3) r.w.s. 147 was quashed as bad in law. Assessee's appeal was allowed. en-us Thu, 12 Sep 2024 00:00:00 +0530 Mon, 12 May 2025 15:17:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461991 ITAT Kolkata held that reopening notice u/s 148 issued by non-jurisdictional AO rendered the assessment invalid. Following SC precedent in Hotel Blue Moon case, the tribunal ruled that jurisdictional AO issuing notice u/s 148 is sine qua non for valid reopening proceedings u/s 147. Since notice was issued by AO lacking jurisdiction over assessee, it was treated as non-est. Assessment framed u/s 143(3) r.w.s. 147 was quashed as bad in law. Assessee's appeal was allowed. Case-Laws Income Tax Thu, 12 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461991