Assessing Officer authority requires specific statutory authorisation; reassessment notice without it is void and uncured by section 292B.

A Joint Commissioner can act as an Assessing Officer only when specifically authorised under section 120(4)(b) to exercise Assessing Officer powers. General territorial or administrative allocation under section 120(1) or section 120(2) does not by itself confer that status. As no specific order under section 120(4)(b) or notification under section 120(6) authorised the Joint Commissioner for the assessee, the reasons recorded and notice under section 148 were without jurisdiction. The defect could not be cured by section 292B, so the reassessment was invalid and liable to be cancelled in favour of the assessee.

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Issues: Whether the Joint Commissioner of Income-tax was an Assessing Officer competent to record reasons and issue notice under section 148, and whether the reassessment initiated on that basis was without jurisdiction.

Analysis: The statutory definition of "Assessing Officer" in section 2(7A) is exhaustive and extends to a Joint Commissioner only when he is directed under section 120(4)(b) to exercise or perform the powers and functions of an Assessing Officer. General territorial or administrative allocation under section 120(1) and section 120(2) does not, by itself, confer that status. The record did not disclose any specific order under section 120(4)(b) or notification under section 120(6) authorising the Joint Commissioner to act as the Assessing Officer for the assessee. In the absence of such authorisation, the notice under section 148 and the reasons recorded under section 148(2) could not be sustained. The defect was not curable under section 292B.

Conclusion: The Joint Commissioner lacked jurisdiction to issue the notice under section 148 and to record the reasons therefor. The reassessment was invalid and liable to be cancelled, in favour of the assessee.

Ratio Decidendi: A Joint Commissioner can exercise Assessing Officer powers only upon specific statutory authorisation under section 120(4)(b); without such authorisation, a reassessment notice under section 148 is without jurisdiction and cannot be saved by section 292B.

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