Reassessment jurisdiction requires valid transfer and timely notice; assessment quashed where these conditions were not satisfied.

A reassessment can proceed only if the case is validly transferred by the competent authority; an Assessing Officer cannot shift jurisdiction on his own, and jurisdiction cannot be created by the assessee's consent or request. Where the notice was issued at the last known address, but no valid notice under Section 148 was issued by the officer who ultimately framed the assessment within the limitation period under Section 149, the assessment lacked jurisdiction. The assessment order was therefore quashed and the additions were deleted.

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Issues: Whether the reassessment proceedings and assessment order were invalid for want of jurisdiction and for absence of a lawful transfer of the case under the Income-tax Act, 1961.

Analysis: The reassessment notice was issued on the last known address when the assessee had not filed a return, and the assessing officer at Panchkula was treated as having jurisdiction for issuing notice. However, transfer of the case to another assessing officer could be made only by the competent authority under Section 127 of the Income-tax Act, 1961. An assessing officer cannot transfer a case on his own, and jurisdiction cannot be conferred by consent or by the assessee's request. Since no valid notice under Section 148 of the Income-tax Act, 1961 was issued by the officer who ultimately framed the assessment within the limitation period under Section 149 of the Income-tax Act, 1961, the assessment was held to be without jurisdiction.

Conclusion: The assessment order was quashed as invalid for want of jurisdiction, and the additions made in the assessment were deleted.

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