Jurisdiction of Additional CIT in assessment was invalid absent transfer order and proper statutory empowerment; assessment quashed.

An assessment framed by an Additional CIT was found invalid because no order on record showed valid conferral of authority under section 120(4)(b) or transfer of jurisdiction under section 127(1) after restructuring of jurisdiction. The statutory scheme permits the Additional CIT to exercise Assessing Officer powers only when properly empowered, and the absence of such jurisdictional authorisation was treated as a fundamental defect. On that basis, the assessment under section 143(3) was quashed and the additional grounds were allowed.

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Issues: Whether the assessment framed by the Additional CIT was without valid jurisdiction in the absence of an order under section 127(1) of the Income-tax Act, 1961 read with section 120(4)(b) of the Income-tax Act, 1961, and whether the assessment under section 143(3) of the Income-tax Act, 1961 was liable to be quashed.

Analysis: The Additional CIT can exercise the powers of an Assessing Officer only when empowered under the statutory framework. In the absence of any order placed on record showing valid conferral of authority under section 120(4)(b) of the Income-tax Act, 1961 and transfer of jurisdiction under section 127(1) of the Income-tax Act, 1961 after the restructuring of jurisdiction, the assessment could not be sustained. The jurisdictional defect was treated as fundamental, and the assessment was held to be invalid in light of the applicable statutory scheme and the coordinate bench view relied upon in the order.

Conclusion: The assessment was held to have been framed without valid jurisdiction and was quashed, with the additional grounds allowed.

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