https://www.taxtmi.com/caselaws?id=469878 Assessment framed by an ITO was held to suffer from lack of pecuniary jurisdiction where the returned loss exceeded the monetary limit prescribed in CBDT Instruction No. 1/2011, placing jurisdiction with the ACIT/DCIT. In the absence of any transfer order under section 127, the ITO's notice under section 143(2) was treated as invalid and not curable because the defect went to the root of jurisdiction. The consequent assessment under section 143(3) read with section 147 was quashed, and once the jurisdictional objection succeeded, the merits of the addition did not survive. en-us Tue, 30 Dec 2025 00:00:00 +0530 Tue, 07 Jul 2026 21:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469878 Assessment framed by an ITO was held to suffer from lack of pecuniary jurisdiction where the returned loss exceeded the monetary limit prescribed in CBDT Instruction No. 1/2011, placing jurisdiction with the ACIT/DCIT. In the absence of any transfer order under section 127, the ITO's notice under section 143(2) was treated as invalid and not curable because the defect went to the root of jurisdiction. The consequent assessment under section 143(3) read with section 147 was quashed, and once the jurisdictional objection succeeded, the merits of the addition did not survive. Case-Laws Income Tax Tue, 30 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469878