Assessment Invalid Due to Jurisdiction Errors; Notice and Transfer Lacked Proper Authority, Revenue's Appeal Dismissed.

The Tribunal upheld the CIT(A)'s decision, concluding that the assessment by the AO, Ward 33(2), was invalid due to jurisdictional errors. The initial notice under Section 148 was issued by AO, Ward 25(4), without proper jurisdiction, and the subsequent assessment by Ward 33(2) was also invalid because it proceeded without a fresh notice. Additionally, the transfer of jurisdiction lacked a formal order under Section 127, further invalidating the proceedings. The Revenue's appeal was dismissed, affirming the assessment's invalidity.

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Issues Involved:
1. Jurisdiction of the Assessing Officer (AO) issuing the notice under Section 148.
2. Validity of the assessment completed by the AO, Ward 33(2), New Delhi.
3. Requirement of fresh notice under Section 148 by the AO, Ward 33(2).
4. Transfer of jurisdiction without an order under Section 127.

Issue-wise Detailed Analysis:

1. Jurisdiction of the Assessing Officer (AO) Issuing the Notice under Section 148:
The primary issue is whether the AO, Ward 25(4), had jurisdiction to issue the notice under Section 148. The AO issued the notice based on information from the Dy. Director of IT (Inv.), Faridabad, indicating that the assessee had introduced funds of Rs. 4,75,000 through an accommodation entry in his bank account using an address under the jurisdiction of Ward 25(4). However, the assessee objected, stating his address was in Karol Bagh, under the jurisdiction of Ward 33(2). The CIT(A) found that the AO, Ward 25(4), did not have jurisdiction over the assessee and thus the notice was invalid.

2. Validity of the Assessment Completed by the AO, Ward 33(2), New Delhi:
The assessment was completed by the AO, Ward 33(2), based on the initial notice issued by the AO, Ward 25(4). The CIT(A) held that since the initial notice was issued without jurisdiction, the subsequent assessment by Ward 33(2) was also invalid. The Tribunal upheld this view, emphasizing that the AO, Ward 33(2), should have issued a fresh notice under Section 148 after the case was transferred.

3. Requirement of Fresh Notice under Section 148 by the AO, Ward 33(2):
The CIT(A) and the Tribunal both agreed that the AO, Ward 33(2), should have issued a fresh notice under Section 148 before proceeding with the assessment. The failure to issue a fresh notice rendered the assessment invalid. The Tribunal noted that the AO, Ward 33(2), merely continued the proceedings without issuing a new notice, which was a procedural lapse.

4. Transfer of Jurisdiction without an Order under Section 127:
The transfer of the case from AO, Ward 25(4) to AO, Ward 33(2) was done without an order under Section 127, which is required for transferring jurisdiction between different AOs. The Tribunal highlighted that the transfer was done merely based on an intimation and without any formal order, further invalidating the proceedings.

Conclusion:
The Tribunal upheld the CIT(A)'s decision that the assessment made by the AO, Ward 33(2), was without jurisdiction and thus invalid. The initial notice under Section 148 was issued without proper jurisdiction, and the subsequent failure to issue a fresh notice under Section 148 by the AO, Ward 33(2), compounded the procedural errors. The appeal filed by the Revenue was dismissed, affirming the invalidity of the assessment proceedings.

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