Assessing Officer jurisdiction depends on specific statutory empowerment; work-allocation alone cannot validate an assessment.

A Joint Commissioner can validly act as an Assessing Officer only if specifically directed under section 120(4)(b) of the Income-tax Act; without that statutory empowerment, an assessment framed under section 143(3) is without jurisdiction and void. A general work-allocation notification does not substitute for the required authorisation. Section 124(3) bars objections to territorial jurisdiction, but it does not cure a complete absence of inherent authority to make the assessment or validate participation in proceedings where jurisdiction is lacking. The note states that an assessment made without such empowerment is liable to be quashed.

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Issues: Whether the assessment orders framed by the Joint Commissioner of Income-tax were without jurisdiction in the absence of an order under section 120(4)(b) of the Income-tax Act, 1961, and whether the objection to such lack of jurisdiction was barred by section 124(3) of the Income-tax Act, 1961.

Analysis: Under section 2(7A) of the Income-tax Act, 1961, a Joint Commissioner can function as an Assessing Officer only when directed under section 120(4)(b) to exercise the powers and functions of an Assessing Officer. The record showed no such order conferring authority on the Joint Commissioner who framed the assessments under section 143(3). The Tribunal held that a notification dealing with allocation of work among subordinate officers did not amount to the requisite statutory empowerment under section 120(4)(b). It further held that section 124(3) concerns objections to territorial jurisdiction and does not cure or validate a complete absence of inherent jurisdiction to frame the assessment. Participation in the assessment proceedings or failure to object within the statutory time could not confer jurisdiction where none existed.

Conclusion: The assessment orders were without jurisdiction and were liable to be quashed. The objection under section 124(3) did not bar the assessee from challenging the very authority of the Joint Commissioner to make the assessments.

Final Conclusion: Both appeals succeeded because the impugned assessments were annulled for want of valid statutory authority in the officer who framed them.

Ratio Decidendi: An assessment framed by a Joint Commissioner is valid only if the officer has been specifically directed under section 120(4)(b) to exercise Assessing Officer powers; absent such empowerment, the assessment is void, and the limitation on challenging territorial jurisdiction under section 124(3) does not apply to a plea of inherent lack of jurisdiction.

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