Dismissing the appeal of the assessee the Court held that; the assessee had not raised any objection after the Assessing Officer at Hyderabad issued notice for appearance. On the contrary, he appeared before the Assessing Officer at Hyderabad and put forth his objections on the merits regarding the reassessment. Even in the two appeals filed by him before the two appellate fora, the assessee had never raised this objection. While the very initiation of proceedings and issue of notices under sections 147 and 148 constituted a jurisdictional issue, which could be raised by the aggrieved party at any point of time and at any stage, the objections regarding non-recording of reasons and non-issue of notice before passing the order of transfer would not go to the root of the matter enabling the aggrieved party to raise these issues for the first time before the High Court not having raised earlier. The reason for this is that these aspects raise mixed questions of fact and law. Unless the assessee had raised these issues before the lower fora, the facts relevant thereto would not come on record. Therefore, the assessee, having not raised the objections with respect thereto before any lower fora, was not entitled to raise them for the first time in these appeals before the court. The assessee had also not pleaded any prejudice on account of transfer or purported absence of reasons for such transfer. The assessment proceedings were valid.( AY. 1992-93 to 1996 -97)