Reassessment notice upheld where jurisdiction, statutory approval, and limitation were satisfied despite a belated territorial challenge.

A reassessment notice is valid where it is issued by the Assessing Officer having territorial and pecuniary jurisdiction, the proposal is approved under section 151, reasons are furnished, and the jurisdictional objection is raised belatedly. The Court applied the statutory definition of Assessing Officer and the jurisdictional scheme under sections 120 and 124 to hold that the reopening could proceed. It found the contrary precedent inapplicable because the notice here was issued by a competent officer within limitation. The writ petition was rejected, and the objections order was upheld.

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Issues: Whether the reassessment notice and the order disposing of objections were jurisdiction and liable to be quashed on the ground that the reopening was initiated by the Assessing Officer having territorial and pecuniary jurisdiction, approval was obtained, reasons were furnished, and the jurisdictional objection was raised belatedly.

Analysis: The petitioner challenged the reopening of the assessment for the relevant year on the basis that the earlier assessment had been completed by a different income-tax authority and, therefore, the officer who issued the notice under section 148 could not reopen the assessment. The Court held that the officer who initiated the reopening was the Assessing Officer having territorial and pecuniary jurisdiction over the case, and that the statutory definition of Assessing Officer together with the jurisdictional scheme under sections 120 and 124 enabled him to proceed. The Court also noted that the proposal for reopening was approved by the sanctioning authority under section 151, and that the objections filed by the petitioner were considered and rejected by a speaking order. The reliance placed on a contrary decision was held to be inapplicable on the facts, since the notice in the present case was issued by a jurisdictionally competent officer and within limitation.

Conclusion: The reopening was held to be valid, the jurisdictional challenge failed, and the objections order was upheld.

Final Conclusion: The writ petition was rejected because the impugned reassessment proceedings were found to be lawful and within jurisdiction.

Ratio Decidendi: A reassessment notice is valid where it is issued by the Assessing Officer having jurisdiction, after statutory approval and within limitation, and a belated challenge to such jurisdiction does not invalidate the proceedings.

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