No assumption of jurisdiction allowable for income tax reassessments without issuance of notice u/s: ITAT

The ITAT held that reassessment proceedings under the Income Tax Act cannot be initiated without first issuing a valid statutory notice under the appropriate section (e.g., Section 148). Without such a notice, the AO lacks the jurisdiction to proceed. This case reaffirms judicial emphasis on procedural compliance in reopening assessments and protects taxpayer rights against arbitrary reassessments.