Jurisdiction after section 127 transfer: reassessment by the former Assessing Officer was void, and consequential additions fell away.

After transfer of the assessee's case under section 127 of the Income-tax Act, 1961, the erstwhile Assessing Officer became functus officio and lacked authority to issue notice under section 148 or complete reassessment under section 143(3) read with section 147. As assumption of jurisdiction is a condition precedent, the reassessment initiated and completed by that officer was void ab initio and without authority of law. Once the reassessment was quashed for want of jurisdiction, the additions made in the assessment could not survive and became academic.

---

---

Issues: Whether the reassessment proceedings initiated by the erstwhile Assessing Officer were invalid for want of jurisdiction after transfer of the assessee's case under section 127 of the Income-tax Act, 1961, and whether the additions on merits could survive once the reassessment was held void.

Analysis: The jurisdiction over the assessee had already been transferred by an order under section 127 of the Income-tax Act, 1961. After such transfer, the original Assessing Officer became functus officio and had no authority to issue notice under section 148 or complete reassessment under section 143(3) read with section 147 of the Income-tax Act, 1961. Since assumption of jurisdiction is a condition precedent, the reassessment initiated and completed by the officer lacking jurisdiction was held to be without authority of law and void ab initio. Once the reassessment was quashed, the additions made in the assessment did not survive for adjudication.

Conclusion: The reassessment proceedings were invalid for want of jurisdiction, and the consequential additions became academic.

---