Pecuniary jurisdiction for reassessment notices is mandatory; initiation by a non-jurisdictional Assessing Officer invalidates consequential assessment proceedings.

Reassessment initiated through an order under section 148A(d) and notice under section 148 must be issued by the Assessing Officer holding the applicable pecuniary jurisdiction. Where CBDT instructions assigned the assessee to a Circle under Range-22, but the order and notice were issued by an Income Tax Officer of Ward 22(1), the defect concerned pecuniary rather than territorial jurisdiction under section 124(3). A reassessment notice issued by an officer lacking jurisdiction is inherently invalid and cannot be cured. The reassessment proceedings and consequential assessment order were therefore quashed for want of jurisdiction.

---

---

Issues: Whether reassessment proceedings initiated through an order under section 148A(d) and notice under section 148 by a non-jurisdictional Assessing Officer were valid.

Analysis: The applicable CBDT jurisdictional instruction assigned the assessee's case to a Circle under Range-22, Delhi, whereas the section 148A(d) order and section 148 notice were issued by the Income Tax Officer, Ward 22(1), Delhi. The defect concerned the issuing officer's pecuniary jurisdiction, rather than territorial jurisdiction governed by section 124(3). A notice initiating reassessment by an officer lacking jurisdiction is inherently invalid and the defect is not curable.

Conclusion: The reassessment proceedings and consequential assessment order were invalid for want of jurisdiction and stood quashed, in favour of the assessee.

---