Jurisdiction for reassessment fails when notice is issued by an unauthorised officer and no valid transfer order exists.

A reassessment initiated by an officer lacking pecuniary jurisdiction is invalid where the case is later moved without a valid transfer order under section 127. The text states that jurisdiction to reopen under sections 147 and 148 must rest on a valid notice by an officer authorised under section 2(7A), and that administrative correspondence cannot substitute for a lawful transfer of jurisdiction. It further notes that section 292BB does not cure the foundational defect in jurisdiction. Because the reassessment was treated as void on this basis, the remaining additions were not examined and were left academic.

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Issues: Whether the reassessment notice and the consequent assessment were without jurisdiction because the notice was issued by an officer lacking pecuniary jurisdiction and the case was later transferred without a valid order of transfer.

Analysis: The appeal turned on jurisdiction. The record showed that the notice under section 148 was issued by the Assistant Commissioner, but the case was subsequently transferred to the Income Tax Officer without a transfer order under section 127. Jurisdiction for reopening depends upon a valid notice issued by the officer having authority under section 2(7A) read with sections 147 and 148. A transfer of jurisdiction cannot be assumed merely by administrative correspondence, and the absence of a valid transfer order is not cured by section 292BB. Once the foundational jurisdictional defect was found, the remaining additions were not examined because they became academic.

Conclusion: The reassessment notice and the assessment framed on its basis were held to be without jurisdiction and invalid.

Final Conclusion: The Revenue's challenge failed on the jurisdictional objection, and the other grounds were left undecided as academic.

Ratio Decidendi: A reassessment initiated by an officer lacking jurisdiction, without a valid transfer of the case under section 127, is void and cannot be sustained.

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