PCIT  may transfer a case from one Assessing Officer subordinate to him, to any other Assessing Officer also subordinate to him, after giving assessee a reasonable opportunity of hearing in this regard and after recording reasons for transferring matter. Notice under section 148 was issued by Asstt. Commissioner, Moradabad to assessee on 3-7-2019. Case of assessee was transferred by Asstt. Commissioner, Circle-1, Moradabad to Dy. Director/Asstt. Director (IT), Lucknow, considering NRI status of assessee but no notice under section 127 was served on assessee before transferring jurisdiction, nor any copy of letter/order for transfer of jurisdiction had ever been served on assessee.On facts, final assessment order passed by Dy. Director/Asstt. Director (IT)  Lucknow under section 147 read with section 144C(13) is  without jurisdiction, non-est, illegal and bad in law. Tribunal also held that where no variation prejudicial to assessee’s interest, at hands of Assessing Officer, had arisen as a consequence of order passed by TPO under section 92CA(2), nor was assessee a foreign company, since neither of conditions prescribed by section 144C(15)(b) were satisfied, assessee was not an ‘eligible assessee’ within meaning of section 144C(15). Passing a draft proposed assessment order under section 144C(1) is not valid. Since  the assessee is not an eligible assessee no draft order was to be forwarded to him, and therefore, requirement of section 144C(12) could not have been complied with, and, limitation to pass assessment order would be one provided under section 153(2).Since notice under section 148 was issued on 3-7-2019 and limitation would have been extended up to 30-9-2021, assessment order passed on 28-6-2022 is   barred by limitation provided under section 153(2).  (AY. 2016-17)