https://www.taxtmi.com/caselaws?id=776651 The ITAT Ahmedabad held that the reassessment initiated under section 147 for A.Y. 2013-14 was invalid as the alleged escapement of income related to an invalidated declaration under the Income Declaration Scheme, 2016, pertaining to A.Y. 2017-18. The AO's jurisdiction to reopen for A.Y. 2013-14 was not supported by the record or statutory provisions. The tribunal emphasized that jurisdictional defects cannot be cured by non-participation and can be raised at the appellate stage. Since the protective addition for A.Y. 2017-18 was already under appeal, the reassessment for the earlier year caused no prejudice to Revenue. Consequently, the reassessment for A.Y. 2013-14 was quashed, and the appeal filed by the assessee was allowed. en-us Tue, 12 Aug 2025 00:00:00 +0530 Thu, 14 Aug 2025 08:26:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776651 The ITAT Ahmedabad held that the reassessment initiated under section 147 for A.Y. 2013-14 was invalid as the alleged escapement of income related to an invalidated declaration under the Income Declaration Scheme, 2016, pertaining to A.Y. 2017-18. The AO's jurisdiction to reopen for A.Y. 2013-14 was not supported by the record or statutory provisions. The tribunal emphasized that jurisdictional defects cannot be cured by non-participation and can be raised at the appellate stage. Since the protective addition for A.Y. 2017-18 was already under appeal, the reassessment for the earlier year caused no prejudice to Revenue. Consequently, the reassessment for A.Y. 2013-14 was quashed, and the appeal filed by the assessee was allowed. Case-Laws Income Tax Tue, 12 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776651