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    <title>2024 (8) TMI 1733 - ITAT KOLKATA</title>
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    <description>Jurisdiction of income-tax authorities under section 120 and the CBDT&#039;s monetary allocation directions was central: because the assessee&#039;s returned loss placed the case outside the ITO&#039;s pecuniary jurisdiction under Instruction No. 1/2011, the reopening notice under section 148 and the completed assessment had to be issued by the ACIT/DCIT. A notice from an officer lacking competence was treated as a root defect, and section 292BB could not cure the absence of a valid notice from the jurisdictional officer. The reassessment was therefore held invalid for want of jurisdiction, and the assessment order was quashed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=468955</link>
      <description>Jurisdiction of income-tax authorities under section 120 and the CBDT&#039;s monetary allocation directions was central: because the assessee&#039;s returned loss placed the case outside the ITO&#039;s pecuniary jurisdiction under Instruction No. 1/2011, the reopening notice under section 148 and the completed assessment had to be issued by the ACIT/DCIT. A notice from an officer lacking competence was treated as a root defect, and section 292BB could not cure the absence of a valid notice from the jurisdictional officer. The reassessment was therefore held invalid for want of jurisdiction, and the assessment order was quashed.</description>
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