Held that  the jurisdictional Assessing Officer of the assessee-trust was the Assistant Commissioner (E), Mumbai and jurisdiction had never been changed or transferred to the ITO, Bareli, the very initiation of reopening by the ITO, Bareli under section 147 / 148 of the Act was bad in law. Under sections 120 and 124 of the Act only the Assistant Commissioner (E), Mumbai was the Assessing Officer of the assessee-trust empowered to frame the assessment, which had never been changed or transferred to ITO, Bareli under section 127 of the Act. The notice under section 148 of the Act having been issued by a non-jurisdictional Assessing Officer, the ITO, Bareli, the reassessment framed by the Assistant Commissioner (E), Mumbai on the basis of initiation of reopening under section 147 / 148 of the Act was not sustainable in the eyes of law for lack of jurisdiction being void ab initio.(AY.2007-08)