Reassessment quashed by lack of Jurisdiction

The Kolkata Bench of the Income Tax Appellate Tribunal (ITAT) quashed reassessment proceedings initiated under Section 148 of the Income-tax Act after holding that the notice had been issued by an Income Tax Officer (ITO) lacking pecuniary jurisdiction under the CBDT’s jurisdictional instructions. 

The Tribunal observed that jurisdiction is a foundational requirement for a valid reassessment and that a notice issued by a non-jurisdictional officer cannot be cured by subsequent assessment proceedings. 

The Tribunal also deleted additions relating to alleged unexplained share capital and notional interest in a separate assessment year after finding that the additions were based on incorrect assumptions and unsupported presumptions.