Reassessment Quashed as ITO Lacked Jurisdiction Under CBDT Instruction

Kshirod Kumar Pattnaik Vs ITO (ITAT Cuttack) Summary: The appeal arose from an order of the Commissioner of Income Tax (Appeals) for Assessment Year 2012-13. The assessee challenged the reassessment proceedings initiated under Sections 147 and 148 of the Income-tax Act, the assessment framed under Sections 144/147, the jurisdiction of the Income Tax Officer (ITO), and the additions made towards alleged unexplained fixed deposits and bank interest. The assessee had originally filed a return declaring total income of ₹35,09,538. Subsequently, a survey conducted by the Investigation Wing revea...