Pankajbhai Jaysukhlal Shah v .ACIT ( 2019 ) 110 taxmann.com 51 / (2020)425 ITR 70/ 185 DTR 306/ 312 CTR 300 (Guj) (HC)/ Editorial: SLP of revenue is dismissed , Add .CIT v. Panjajbhai Jaysuklal Shah ( 2020) 275 Taxman 99 (SC)

S.147: Reassessment —Officer recording reasons and issuing notice must be the jurisdictional Assessing Officer — Reasons recorded by jurisdictional Assessing Officer – E. assessment Scheme – Notice issued by officer who did not have jurisdiction over assessee — Defect not curable- Notice and consequential proceedings and order invalid [ S.148 , 292B ]