Reassessment by a non-jurisdictional officer fails where reopening lacks lawful authority and cannot sustain the addition.

Reassessment under section 148 was held unsustainable where the notice and reopening were initiated by a non-jurisdictional officer lacking lawful authority at the relevant stage. The reopening machinery must be set in motion by a legally competent officer on legally sustainable material, and it cannot operate as a mere review or change of opinion after full and true disclosure in the original section 143(3) assessment. Because the reassessment itself failed for want of jurisdiction, the consequent assessment and addition could not survive and were deleted.

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Issues: Whether reassessment proceedings initiated under section 148 by a non-jurisdictional officer were valid and whether the consequent assessment and addition could be sustained.

Analysis: The assessee's original return had been processed in the regular course and reassessment was initiated on the basis of a notice issued by an officer who did not have jurisdiction over the case at the relevant stage. The record and the cited authorities were relied upon to hold that valid reopening requires a legally competent officer to record the reasons and set the reassessment machinery in motion. The decision also proceeded on the settled principle that where the assessee has made full and true disclosure in the original assessment completed under section 143(3), reopening cannot be used as a mere review or as a change of opinion, and the reopening must rest on lawful jurisdiction and legally sustainable material.

Conclusion: The reassessment initiation was held to be unsustainable in law, and the assessment based on it could not survive; the addition was deleted.

Ratio Decidendi: A reassessment founded on a notice issued by a non-jurisdictional officer is invalid, and where the reopening itself fails for want of lawful jurisdiction, the resulting assessment and additions cannot be sustained.

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