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    <title>2026 (4) TMI 721 - ITAT DELHI</title>
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    <description>A scrutiny assessment was treated as jurisdictionally invalid where the notice under section 143(2) was issued by an officer not competent under CBDT Instruction No. 1/2011 read with section 119 of the Income-tax Act, 1961. The instruction allocated jurisdiction by pecuniary limits, and on the stated facts the declared income fell below the threshold for the Assistant Commissioner, so the power to issue the notice vested in the Income-tax Officer. The additional ground was entertained as a pure question of law, and the defect was treated as distinct from concurrent territorial jurisdiction. The assessment under section 143(3) was therefore quashed.</description>
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      <title>2026 (4) TMI 721 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=789652</link>
      <description>A scrutiny assessment was treated as jurisdictionally invalid where the notice under section 143(2) was issued by an officer not competent under CBDT Instruction No. 1/2011 read with section 119 of the Income-tax Act, 1961. The instruction allocated jurisdiction by pecuniary limits, and on the stated facts the declared income fell below the threshold for the Assistant Commissioner, so the power to issue the notice vested in the Income-tax Officer. The additional ground was entertained as a pure question of law, and the defect was treated as distinct from concurrent territorial jurisdiction. The assessment under section 143(3) was therefore quashed.</description>
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