Jurisdiction to complete assessment requires valid transfer and express authorisation; an Additional Commissioner acted without authority here.

An assessment order made by an Additional Commissioner was held invalid where the record showed neither a transfer of jurisdiction under section 127 nor a specific authorisation under section 120(4)(b). The statutory scheme permits an Additional Commissioner to act as an Assessing Officer only when expressly directed to exercise those powers and functions. In the absence of such lawful empowerment, the officer lacked jurisdiction to complete the assessment, rendering the order without authority and liable to be annulled in favour of the assessee.

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Issues: Whether the assessment order passed by the Additional Commissioner of Income-tax was valid when no order transferring the case under section 127 and no specific authorization under section 120(4)(b) was shown.

Analysis: The assessment had been initiated by another Assessing Officer, and the record did not contain any order under section 127 transferring the proceedings to the Additional Commissioner. The statutory scheme treated an Additional Commissioner as an Assessing Officer only when specifically directed under section 120(4)(b) to exercise or perform the powers and functions of such an officer. In the absence of both a valid transfer order and the requisite authorization, the Additional Commissioner could not assume jurisdiction to complete the assessment. The assessment was therefore made without lawful authority and was liable to be annulled.

Conclusion: The assessment order was invalid and void for want of jurisdiction and was quashed, in favour of the assessee.

Ratio Decidendi: An assessment can be completed by the officer who has lawful jurisdiction over the case, and an Additional Commissioner can exercise Assessing Officer powers only when specifically authorized under section 120(4)(b); without a valid transfer under section 127, the assessment is without jurisdiction.

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