Assessee-company, a non-resident company, was under jurisdiction of Deputy Commissioner, International tax, circle-1(1)(1), New Delhi.  Reopening notice was issued by ACIT, International Taxation, Bhubaneswar on ground that assessee had business income arising in India in respect of management consultancy fees paid to it by its Indian AE. The assessee filed an application for lower deduction certificate under section 197 wherein assessee itself mentioned its address at Odisha  The reassessment notices were challenged on the ground that Assessing Officer at Bhuvaneswar had no jurisdiction to issue. Allowing the petition the Court held that  since department was not able to explain legal basis for ACIT, Bhubaneswar exercising jurisdiction over assessee, notices issued by ACIT, IT, Bhubaneswar were without jurisdiction  accordingly the  notices and all proceedings consequent thereto are quashed. (AY. 2013-14 to 2017-18)