Reopening u/s 148A(b) doesn't imply jurisdiction overreach; distinguishes between jurisdictional errors and errors within jurisdiction.

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....Reopening of assessment - notice under Section 148A(b) - it is not a case where from bare reading of notice it can be axiomatically held that the authority has clutched upon the jurisdiction not vested in it. By now it is well settled that there is vexed distinction between jurisdictional error and error of law/fact within jurisdiction. For rectification of errors statutory remedy has been provided. - HC....