Reassessment Quashed for Lack of Jurisdiction: AO Became Functus Officio After Section 127 Transfer

ITO Vs Sourabh Navalkishor Garg (ITAT Mumbai) Mumbai ITAT upheld the CIT(A)’s decision quashing reassessment proceedings, holding that assessment framed by an AO without jurisdiction is void ab initio. The Tribunal observed: Jurisdiction over the assessee was transferred u/s 127 on 20.10.2010 from ACIT, Ajmer to DCIT, Mumbai Despite this, the Ajmer AO issued notice u/s 148 (28.03.2014) and completed reassessment As highlighted in the timeline table (page 9), the entire reassessment was conducted by an officer who had already lost jurisdiction The ITAT held: Once jurisdiction is transferre...