Jurisdictional defect in reassessment notice renders the entire reassessment void when no valid transfer or fresh notice exists.

Reassessment proceedings were held void where the notice initiating reassessment was issued by an officer lacking jurisdiction, while the assessment was completed by another officer without a valid transfer order or a fresh notice by the competent authority. The absence of a proper jurisdictional foundation meant the statutory precondition for reassessment was not satisfied, and the defect went to the root of the matter. As a result, the reassessment and all consequential proceedings were treated as non est and quashed.

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Issues: Whether reassessment proceedings were valid where the notice under section 148 was issued by one Assessing Officer lacking jurisdiction, while the assessment under sections 147 and 143(3) was framed by another Assessing Officer without a transfer order under section 127.

Analysis: The notice initiating reassessment was issued by an officer stated to be without valid jurisdiction. The assessment was thereafter completed by a different officer who was said to have jurisdiction, but no notice under section 148 was issued by that officer and no order transferring the case under section 127 was shown. On these facts, the statutory precondition for valid reassessment was not satisfied. An order made without jurisdiction is a nullity, and consequential proceedings cannot survive where the initiating notice itself is invalid and the jurisdictional defect goes to the root of the matter.

Conclusion: The reassessment proceedings were invalid and were quashed; the cross-objection succeeded and the revenue's appeal failed to survive.

Ratio Decidendi: Where reassessment is initiated by an authority lacking jurisdiction, and the jurisdictional defect is not cured by a valid transfer order or a proper notice by the competent authority, the entire reassessment is void and all consequential proceedings are non est.

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