Section 158BD jurisdiction fails where satisfaction is not properly recorded and jurisdictional transfer under section 127 is absent.

Block assessment proceedings under section 158BD require the seized material to be transmitted to the Assessing Officer having jurisdiction over the other person, with proper satisfaction recorded before valid jurisdiction is assumed. The record also showed that the notice was issued after a change in jurisdiction, but no intimation order under section 127 was available. Because the satisfaction note was recorded by an officer other than the jurisdictional Assessing Officer who issued the notice, the statutory conditions for assuming jurisdiction were not duly complied with, and the block assessment was held invalid and liable to be quashed.

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Issues: Whether the block assessment initiated under section 158BD was vitiated for want of proper satisfaction by the jurisdictional Assessing Officer and for non-compliance with the requirement of intimation of change of jurisdiction under section 127.

Analysis: The proceedings were examined in light of the statutory scheme of block assessment under section 158BD, which requires the seized material to be handed over to the Assessing Officer having jurisdiction over the other person and the assessment to proceed only after the requisite satisfaction is recorded. The record also showed that the notice was issued after a change in jurisdiction, but no order intimating the transfer under section 127 was available. The satisfaction note was found to have been recorded by an officer other than the jurisdictional Assessing Officer who issued the notice, and the statutory requirements for assuming valid jurisdiction were held not to have been duly complied with.

Conclusion: The block assessment proceedings were held to be invalid and liable to be quashed, and the assessee succeeded.

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