Assessing Officer's Pecuniary Jurisdiction Under Section 120(3) Valid Despite Territorial Reassignment; Enhancement Under 41(1) Remanded

AO's jurisdiction was challenged regarding notice u/s 143(2) after territorial reassignment. ITAT determined that jurisdictional challenges fall under Part B, Chapter XIII, requiring administrative consideration first. Neither ITO nor ACIT lacked territorial jurisdiction; the change merely reflected pecuniary jurisdiction under s.120(3). Following precedents from Kalinga Institute and Mantoo Sarkar cases, ITAT ruled pecuniary jurisdiction challenge as untimely and curable. Regarding sundry creditors, CIT(A)'s enhancement under s.41(1) was found procedurally flawed. Matter remanded to AO for determining creditors' genuineness and appropriate year-wise additions, subject to statutory limitations. Assessee directed to furnish complete documentation for accurate assessment. .....

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