Reasons for reopening recorded by authority not having territorial jurisdiction is bad-in-law

Pritthvi Global Ventures Pvt Limited Vs DCIT (ITAT Kolkata) ITAT Kolkata held that reasons for reopening of the assessment recorded by an Authority who was not having territorial jurisdiction over the assessee is unsustainable in law and accordingly the entire reassessment proceeding is liable to be quashed. Facts- The assessee has shown long-term capital gain at Rs.7,31,66,678/- in the original return of income. It claimed set off of brought forward long-term capital loss of A.Y. 2004-05 amounting to Rs.2,97,870/-. The assessment order thereafter is silent about the status of the original ret...