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    <title>Pecuniary jurisdiction under CBDT instruction invalidated notice issued by officer lacking competence, quashing the assessment.</title>
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    <description>CBDT Instruction No. 1 of 2011 issued under section 119 was held to govern pecuniary jurisdiction for issuance of notice under section 143(2). As the assessee&#039;s declared income fell below the limit placing jurisdiction with the Income Tax Officer in a metro city, the ACIT lacked competent pecuniary jurisdiction to assume assessment jurisdiction under section 143(3). The defect was treated as a foundational jurisdictional error, not a mere issue of concurrent jurisdiction. The Tribunal distinguished the Revenue&#039;s reliance on a different High Court ruling concerning search-related and territorial jurisdiction. The assessment was therefore vitiated and quashed, and the assessee&#039;s additional ground was allowed.</description>
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    <pubDate>Sat, 11 Apr 2026 08:53:11 +0530</pubDate>
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      <title>Pecuniary jurisdiction under CBDT instruction invalidated notice issued by officer lacking competence, quashing the assessment.</title>
      <link>https://www.taxtmi.com/highlights?id=98695</link>
      <description>CBDT Instruction No. 1 of 2011 issued under section 119 was held to govern pecuniary jurisdiction for issuance of notice under section 143(2). As the assessee&#039;s declared income fell below the limit placing jurisdiction with the Income Tax Officer in a metro city, the ACIT lacked competent pecuniary jurisdiction to assume assessment jurisdiction under section 143(3). The defect was treated as a foundational jurisdictional error, not a mere issue of concurrent jurisdiction. The Tribunal distinguished the Revenue&#039;s reliance on a different High Court ruling concerning search-related and territorial jurisdiction. The assessment was therefore vitiated and quashed, and the assessee&#039;s additional ground was allowed.</description>
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      <pubDate>Sat, 11 Apr 2026 08:53:11 +0530</pubDate>
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