ITAT Quashes Assessment for Lack of Jurisdiction: "Reason to Believe" Framed by Non-Jurisdictional AO Held Invalid

The Income Tax Appellate Tribunal (ITAT) has quashed an assessment for lack of jurisdiction, ruling that the "reason to believe" was framed by a non-jurisdictional AO (Assessing Officer) and held invalid. This significant decision protects taxpayers from assessments initiated by officers who do not have proper territorial or functional authority. The ITAT emphasized that the fundamental requirement of 'reason to believe' (for reassessment) must be established by an AO with valid jurisdiction. This ruling reinforces procedural safeguards, ensuring that tax proceedings are initiated only by competent authorities.