https://www.taxtmi.com/caselaws?id=434016 An Assessing Officer at Bhubaneswar could not validly issue a reassessment notice to a non-resident assessee when the jurisdiction record showed the case with the International Taxation office at New Delhi and no transfer order under Section 127 was produced. Section 120 permits internal allocation of functions, but a transfer between non-subordinate assessing authorities requires a lawful Section 127 order and an opportunity of hearing. The reliance on later material, including a lower deduction certificate, did not establish that jurisdiction had shifted for the relevant assessment years. The notice under Section 148, and all consequential proceedings, were therefore held void for want of jurisdiction. en-us Thu, 09 Feb 2023 00:00:00 +0530 Tue, 14 Feb 2023 09:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=434016 An Assessing Officer at Bhubaneswar could not validly issue a reassessment notice to a non-resident assessee when the jurisdiction record showed the case with the International Taxation office at New Delhi and no transfer order under Section 127 was produced. Section 120 permits internal allocation of functions, but a transfer between non-subordinate assessing authorities requires a lawful Section 127 order and an opportunity of hearing. The reliance on later material, including a lower deduction certificate, did not establish that jurisdiction had shifted for the relevant assessment years. The notice under Section 148, and all consequential proceedings, were therefore held void for want of jurisdiction. Case-Laws Income Tax Thu, 09 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=434016