https://www.taxtmi.com/caselaws?id=463210 The ITAT held that reopening of assessment under section 147 requires issuance of notice under section 148 by a competent authority with pecuniary jurisdiction as per CBDT instructions. A subordinate officer cannot assume jurisdiction of a senior officer, and vice versa. Section 292BB protects service of valid notices but does not validate notices issued without jurisdiction. Section 292B does not protect notices issued without jurisdiction either. Since the AO issuing the section 148 notice lacked pecuniary jurisdiction, the notice was invalid. The appeal of the assessee was allowed. en-us Mon, 29 Jul 2024 00:00:00 +0530 Fri, 20 Feb 2026 17:42:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463210 The ITAT held that reopening of assessment under section 147 requires issuance of notice under section 148 by a competent authority with pecuniary jurisdiction as per CBDT instructions. A subordinate officer cannot assume jurisdiction of a senior officer, and vice versa. Section 292BB protects service of valid notices but does not validate notices issued without jurisdiction. Section 292B does not protect notices issued without jurisdiction either. Since the AO issuing the section 148 notice lacked pecuniary jurisdiction, the notice was invalid. The appeal of the assessee was allowed. Case-Laws Income Tax Mon, 29 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463210