https://www.taxtmi.com/caselaws?id=792903 A jurisdictional objection under section 147 must be decided before any remand, because the first appellate authority cannot avoid a foundational challenge by sending the matter back for fresh assessment. The note also explains that reassessment is vitiated when the reasons and sanction papers refer to a non-existent provision, as that points to mechanical approval and non-application of mind. Such a defect goes to the root of reopening and is not cured by section 292B. The reassessment and consequential assessment were therefore treated as invalid. en-us Fri, 15 May 2026 00:00:00 +0530 Fri, 05 Jun 2026 08:07:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792903 A jurisdictional objection under section 147 must be decided before any remand, because the first appellate authority cannot avoid a foundational challenge by sending the matter back for fresh assessment. The note also explains that reassessment is vitiated when the reasons and sanction papers refer to a non-existent provision, as that points to mechanical approval and non-application of mind. Such a defect goes to the root of reopening and is not cured by section 292B. The reassessment and consequential assessment were therefore treated as invalid. Case-Laws Income Tax Fri, 15 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792903