https://www.taxtmi.com/caselaws?id=790703 A scrutiny notice that expressly relied on CBDT Instruction No. 5/2017 was invalid because the mandatory precondition for manual selection was not met: there were no prior additions in earlier assessment years on a recurring issue of law, and the stated monetary threshold was not otherwise satisfied. Since instructions under section 119 bind the Revenue, non-compliance went to the root of jurisdiction and could not be cured under section 292BB. The resulting notice under section 143(2) and the assessment based on it were therefore unsustainable, and the jurisdictional challenge succeeded. en-us Fri, 17 Apr 2026 00:00:00 +0530 Tue, 28 Apr 2026 17:41:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790703 A scrutiny notice that expressly relied on CBDT Instruction No. 5/2017 was invalid because the mandatory precondition for manual selection was not met: there were no prior additions in earlier assessment years on a recurring issue of law, and the stated monetary threshold was not otherwise satisfied. Since instructions under section 119 bind the Revenue, non-compliance went to the root of jurisdiction and could not be cured under section 292BB. The resulting notice under section 143(2) and the assessment based on it were therefore unsustainable, and the jurisdictional challenge succeeded. Case-Laws Income Tax Fri, 17 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790703