Tribunal Examines Jurisdiction Issue u/s 147 of Income Tax Act; Consent Cannot Confer Jurisdiction Authority.

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....Reopening of assessment u/s 147 - Issue of jurisdiction u/s 147 has been raised for the first time before the Tribunal- If an authority is found to have no jurisdiction to invoke reopening of a completed assessment, the consent or waiver can never give the jurisdiction to the authority concerned.....