Reassessment jurisdiction fails when a notice is issued by an officer without territorial authority and no fresh reasons are recorded.

Reassessment under section 148 was held invalid where the notice was issued by an officer lacking territorial jurisdiction over the assessee and the jurisdictional officer did not independently record fresh reasons or issue a fresh notice at the correct address. The assessee had filed the return with the proper jurisdictional officer and disclosed the correct address, but the reopening was initiated by another officer without jurisdiction. Because the statutory conditions for valid assumption of reassessment jurisdiction were not complied with, the reopening was treated as void and the reassessment order was set aside.

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Issues: Whether the reassessment proceedings initiated under section 148 were valid when the notice was issued by an officer lacking jurisdiction over the assessee and the jurisdictional officer did not independently record reasons or issue notice on the correct address.

Analysis: The assessee had filed the return with the officer having territorial jurisdiction and had disclosed the correct address. The reassessment was initiated by another officer who did not have jurisdiction over the assessee. When the file was transferred to the jurisdictional officer, he did not record fresh reasons for reopening or issue a fresh notice under section 148. The power to reopen could be exercised only by the officer having jurisdiction and only after compliance with the statutory conditions for reassessment. Since those requirements were not fulfilled, the reopening lacked valid assumption of jurisdiction.

Conclusion: The reassessment proceedings were invalid and the reassessment order was set aside.

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