Section 292B Cannot Cure Jurisdictional Defect in Reopening

Doriswamy Gopi Vs ITO (ITAT Bangalore) Reopening Quashed for Wrong Assumption That No Return Was Filed — Section 292B Cannot Cure Jurisdictional Defect The Bangalore ITAT (SMC Bench) quashed the reassessment for AY 2017-18 holding that the reopening under section 147 was initiated on a patently incorrect assumption of fact—that the assessee had not filed a return of income—when, in fact, the return had been filed on 18.11.2017. The Tribunal noted that this incorrect assumption was recorded twice in the reasons and could not be brushed aside as a typographical error. Relying on Sagar Ente...