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Court Clarifies AO's Jurisdiction in Assessment Reopening u/s 147; No Need for Section 124(2) Referral.
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....Reopening of assessment u/s 147 - AO jurisdiction in issuing notice - Once the territorial jurisdiction of respondent no.1 is admitted by the petitioner, there existed no occasion for the Assessing Officer to refer the matter for determination under sub-section (2) of Section 124 before the assessment was made. - Merely because some pecuniary limit has been fixed for purpose of distribution of work between officers, it would not mean that there shall be inherent lack of jurisdiction of AO - HC....