Jurisdictional Notice Void

In a jurisdictional challenge to reassessment, the Tribunal ruled that issuance of notice under Section 148 by an authority not empowered under CBDT Instruction No. 1/2011 renders the entire proceedings invalid. 

Where monetary limits allocate jurisdiction to a specific officer, deviation is not a procedural irregularity but a substantive defect. The ruling reinforces that jurisdictional compliance is foundational to valid reassessment.