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    <title>2026 (7) TMI 389 - ITAT AHMEDABAD</title>
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    <description>Reassessment under section 147 was invalid where the Assessing Officer who issued the notice and completed the assessment lacked jurisdiction over the assessee. The Tribunal accepted that jurisdiction lay with a different Assessing Officer, noted that the jurisdictional objection had been raised, and found the jurisdictional fact unrebutted. It held that a notice issued by an without vested jurisdiction is a substantive defect affecting the power to reopen, not a mere technical irregularity, and that section 292BB could not cure notice issued by an incompetent authority. The reassessment was therefore held bad in law and the assessment order was quashed; remaining grounds were treated as academic.</description>
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    <pubDate>Tue, 19 May 2026 00:00:00 +0530</pubDate>
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      <title>2026 (7) TMI 389 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=794503</link>
      <description>Reassessment under section 147 was invalid where the Assessing Officer who issued the notice and completed the assessment lacked jurisdiction over the assessee. The Tribunal accepted that jurisdiction lay with a different Assessing Officer, noted that the jurisdictional objection had been raised, and found the jurisdictional fact unrebutted. It held that a notice issued by an without vested jurisdiction is a substantive defect affecting the power to reopen, not a mere technical irregularity, and that section 292BB could not cure notice issued by an incompetent authority. The reassessment was therefore held bad in law and the assessment order was quashed; remaining grounds were treated as academic.</description>
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      <pubDate>Tue, 19 May 2026 00:00:00 +0530</pubDate>
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