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Assessment jurisdiction depends on a valid statutory transfer where scrutiny proceedings move between Assessing Officers. An administrative proforma, without a transfer order under section 127, does not confer jurisdiction on the successor officer, even where that officer has pecuniary jurisdiction. Scrutiny notice validity also depends on service within six months from the end of the financial year in which the return is furnished under section 143(2). A notice issued after that period cannot be treated as valid merely because proceedings were administratively transferred. These requirements determine whether assessment proceedings can be sustained.
Assessment jurisdiction depends on a valid statutory transfer where scrutiny proceedings move between Assessing Officers. An administrative proforma, without a transfer order under section 127, does not confer jurisdiction on the successor officer, even where that officer has pecuniary jurisdiction. Scrutiny notice validity also depends on service within six months from the end of the financial year in which the return is furnished under section 143(2). A notice issued after that period cannot be treated as valid merely because proceedings were administratively transferred. These requirements determine whether assessment proceedings can be sustained.
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