Reopening Assessment Depends on Authority's Jurisdiction; Consent Cannot Grant Jurisdiction Lacking by Law. Section 292BB Not Applicable.

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....Validity of reopening of assessment - jurisdiction of notice issuing authority - A jurisdiction can neither be waived nor created even by consent and even by submitting to jurisdiction, an Assessee cannot confer upon any jurisdictional authority, something which he lacked inherently. Therefore the contention of DR regarding applicability of section 292BB also does not hold water in favour of the revenue. - AT....