Assessing officer jurisdiction requires specific statutory authorisation; section 144A guidance cannot substitute for assessment power.

Jurisdiction to act as assessing officer depended on statutory vesting under sections 2(7A) and 120, read with the relevant CBDT notifications and instructions. The Tribunal held that the notification permitting Jt. CITs to perform assessing officer functions applied only where the CIT had specifically authorised that officer for the assessee's case, and no such authorisation for the Addl. CIT was shown on the record. It further held that proceedings under section 144A did not allow the Addl. CIT to take over the assessment role, because that provision separates supervisory guidance from assessment authority. The assessment order was therefore without jurisdiction and liable to be quashed.

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Issues: Whether the Addl. CIT had jurisdiction to act as the assessing officer and pass the assessment order, particularly in the absence of a specific authorization under the statutory scheme and in the context of proceedings under section 144A.

Analysis: The statutory framework under sections 2(7A) and 120 makes the power to act as an assessing officer dependent on vesting of jurisdiction by directions or orders issued under the Act. The Tribunal read the relevant CBDT notifications and instructions together and held that the notification authorising Jt. CITs to perform the functions of assessing officers operated only where the CIT had specifically authorised them. On the material placed before it, no such authorisation in favour of the Addl. CIT for the assessee's case was shown. The Tribunal further held that invocation of section 144A did not permit the Addl. CIT to assume the role of assessing officer and complete the assessment himself, because that provision contemplates separate roles of guidance and assessment.

Conclusion: The Addl. CIT lacked jurisdiction to pass the assessment order, which was therefore without authority and liable to be quashed.

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