Jurisdiction for Section 148 notice failed after transfer of records, so the reassessment was quashed.

Where case records had been transferred to the Exemption Ward, a notice under section 148 issued by the earlier officer was invalid because the Revenue did not establish that he retained jurisdiction. The reassessment proceedings could not survive once the authority to issue the reopening notice was not shown to exist. The ITAT Delhi held the reassessment to be without jurisdiction and quashed it, with the assessee succeeding.

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Issues: Whether reassessment proceedings were void for want of jurisdiction where the case records had been transferred to the Exemption Ward but notice under section 148 was issued by the earlier officer without established jurisdiction.

Analysis: The case records had been moved from the Bulandshahr office to the Ghaziabad Exemption office on the premise that the assessee was a registered society. After such transfer, the earlier officer issued notice under section 148. The Revenue did not establish that this officer retained valid jurisdiction to issue the notice. Once the jurisdiction for issuance of notice under section 148 was not shown to exist, the subsequent reassessment proceedings could not stand.

Conclusion: The reassessment was held to be without jurisdiction and was quashed. The assessee succeeded.

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