ITAT Delhi Quashes Reassessment for Lack of Jurisdiction – Notice by Wrong AO Invalid

Late Sh. Sulekh Chand Jain Vs ITO (ITAT Delhi) Background Assessee had always been assessed at Delhi jurisdiction. Reopening reasons (14.12.2021) were recorded by ITO, Ward-2, Rohtak based on Investigation Wing inputs. AO alleged assessee failed to disclose LTCG of ₹3.38 Cr. in ITR. Assessee argued reopening was void since Rohtak AO had no territorial jurisdiction; relied on Col. Paramjit Singh v. CIT (220 ITR 446, P&H) & Dushyant Kumar Jain v. DCIT (381 ITR 428, Del). CIT(A)-NFAC upheld reopening, stating faceless regime makes territorial jurisdiction irrelevant. Tribunal’s Obse...