Judgment :- Radhakrishnan, J. The question that arises for consideration in this case is whether block assessment under Chapter XIV B of the Income Tax Act, 1961 would fall within the meaning of “case” in Explanation to Section 127 of the Income Tax Act enabling the Chief Commissioner of Income Tax to transfer block assessment to a subordinate officer. 2. The assessee was borne on the rolls of the Income Tax Officer, Ward I, Mercara. Original assessee expired after the proceedings in the appeal and is now represented by his son, the legal heir. The original assessee was atimber merchant having business interests in Mattanur in Kerala State and Mercara in Karnataka State. Search was conducted by the Income Tax Department on 22.11.1995 in the residence and business premises of the assessee, his sons and other associates. Consequent to the search proceeding under Section 132 of the Income Tax Act it was proposed to transfer the case to the Income Tax (Inv.) Circle, Calicut to facilitate effective and co-ordinate investigation. The Chief Commissioner of Income Tax, Bangalore, Karnataka in exercise of the powers under section 127 (2) of the Income tax Act transferred the case of the assessee to the jurisdiction of the Assistant Commissioner of Income Tax, Investigation Circle I, Calicut, Kerala, vide proceedings dated 28.2.1996. The assessing officer issued a notice under Section 158 BC to file a return setting forth the total income including undisclosed income for the block period. 3. The assessee filed a writ petition in the High Court of Karnataka challenging the order passed by the Chief Commissioner of Income Tax, Bangalore, contending that the show cause notice issued by the Chief Commissioner did not contain the entire reasons which prompted him to pass the impugned order. The High Court rejected the plea of the assessee and dismissed the writ petition on 8.8.1996. Against that judgment, Writ Appeal Nos.8551 and 8552 were filed and the appeals were dismissed on 10.10.1996. 4. The assessing authority then issued notice under Section 158 BC to file a return setting forth total income including the undisclosed income for the block period. The assessee filed return showing Rs.1,05,752/- as undisclosed income for the block period 1986-87 to 1996-97. The assessing authority however passed an order on 27.11.1996 under Section 158 BC determining the undisclosed income of the assessee as Rs.1,08,63,992/-. The assessee filed return showing Rs.1,05,752/- as undisclosed income for the block period 1986-87 to 1996-97. The assessing authority however passed an order on 27.11.1996 under Section 158 BC determining the undisclosed income of the assessee as Rs.1,08,63,992/-. Aggrieved by the said order assessee preferred appeal before the Income Tax Appellate Tribunal, Cochin Bench. Various contentions were raised by the assessee before the Tribunal. One of the contentions raised by the assessee before the Tribunal was that the Assistant Commissioner of Income Tax, Investigation Circle I, Calicut did not get jurisdiction to make the block assessment and that such jurisdiction still remained with the Assessing Officer organically having jurisdiction over the assessee under Section 2 (7A) of the Income Tax Act. 5. Counsel for the assessee Sri. C. Kochunni Nair submitted that only Income Tax officer, Mercara who conducted search on 22.11.1995 has jurisdiction to make assessment for the block period in accordance with the provisions contained in Chapter XIV-B. Counsel submitted, even though the Chief Commissioner of Income Tax, Bangalore has passed an order under Section 127 (2) of the Income Tax Act on 28.2.1996 transferring the file to the Assistant Commissioner, Investigation, Circle I, Calicut, he can transfer only a case in relation to any proceedings under the Act in respect of any year. Counsel also submitted that the Chief Commissioner of Income Tax could have transferred only a case in relation to any “proceedings under the Act in respect of any year”. Counsel submitted that the assessment for the block period in accordance with the provisions contained in Chapter XIV B is different from a regular assessment and also different from “proceedings” under the Act in respect of any year, as mentioned in the explanation. 6. Senior Standing Counsel for the Revenue Sri P.K. Ravindranatha Menon refuted the contentions and submitted that the Chief Commissioner had passed order under Section 127 (2) after hearing the assessee and the order was challenged before the High Court of Karnataka, but without any success. Counsel also submitted that the word “case” in relation to an assessee means all proceedings under the Act which were pending on the date of the order. Counsel also submitted that the word “case” in relation to an assessee means all proceedings under the Act which were pending on the date of the order. Counsel submitted that Income Tax Officer, Mercara could not have taken action for the block assessment in view of the provisions of Section 158 BC of the Act and so the case had to be transferred to Assistant Commissioner of Income tax has got power to effect such transfer. The Tribunal found no illegality in the order passed by the Chief Commissioner transferring the case to Assistant Commissioner of Income tax, Calicut. After considering the contentions of both sides, the Tribunal remanded the matter back to the assessing officer to consider the entire issue afresh and make proper assessment in accordance with law. Aggrieved by this order, this appeal has been preferred. Identical legal question has also been raised in another writ petition and hence we posted both the cases together. 7. Counsel on either side explained to us the meaning and scope of block assessment and the reasons for the introduction of Chapter XIV B which deals with special procedure for assessment in search cases. Section 158 BB shows how undisclosed income of the block period has to be computed. Procedure to be followed for block assessment has been explained in Section 158 BC. Section 158 BD deals with undisclosed income of any other person. Section 158 BE deals with time limit for completion of block assessment. Section 158 BG states that the order of assessment for the block period shall be passed by an Assessing Officer not below the rank of an Assistant Commissioner or Deputy Commissioner or Assistant Director or Deputy Director, as the case may be. 8. The question mainly urged before us by the counsel for the petitioner is whether the Chief Commissioner has got the power to transfer the case relating to block assessment to the Assistant Commissioner of Income Tax, Calicut. Counsel submitted power is conferred only on the Central Board of Direct Taxes under Section 120 of the Act and not on the Chief Commissioner so far as block assessment is concerned. Counsel laid considerable stress on the word “case” and on the words “in respect of” and the expression “any year”. Counsel submitted when explanation to Section 120 was added concept of block assessment was not in vogue. Counsel laid considerable stress on the word “case” and on the words “in respect of” and the expression “any year”. Counsel submitted when explanation to Section 120 was added concept of block assessment was not in vogue. Therefore the expression “case” would take in only with regard to case relating to a particular year and not years. Counsel submitted that the expression in respect of any year would make the situation very clear. Legislature has not used the expression “cases” or “years”. Counsel made reference to the decision of the apex court in P.V. Narasimha Rao v. State (CBI/SPE) (1998 (4) SCC 626) and submitted that the correct interpretation of the expression “in respect of” cannot be made under any rigid formula but must be appreciated with reference to the context in which it has been used and the purpose to be achieved under the provision in question. Counsel submitted that the expression “case” was inserted using the word “in respect of” after the decision of the apex Court in Bidi Supply Co. v. Union of India and others (29 ITR 717). Counsel also placed reliance on the description given by the Department before the Supreme Court in S.L.P. No 1545/55/1998 (CIT v. Sasidharan), which according to the counsel supports his reasoning. 9. Senior Counsel appearing for the Revenue submitted that block assessment could be handled only by an officer not below the rank of an Assistant Commissioner and the Chief Commissioner has rightly transferred the file to Assistant Commissioner, Calicut. Counsel for the Revenue submitted that the expression “case” used in the explanation has to be given a wider meaning and would take in block assessment as well, which includes number of years. Placing reliance on Section 127 counsel submitted that the word “any” has to be given a wider meaning which would take in assessment which would include block assessment as well Counsel further submitted that in view of Section 127 provision relating to assessment and being a machinery provision the court should give interpretation which makes the provision workable. Counsel also referred to the decision in 48 ITR 4. Counsel also submitted that the stand taken by the Revenue in the Supreme Court would not preclude the court from giving a correct interpretation of the provisions. Counsel made reference to the decision of the Supreme Court in Salem Co-operative Central Bank Ltd. v. C.I.T. (201 ITR 697). Counsel also referred to the decision in 48 ITR 4. Counsel also submitted that the stand taken by the Revenue in the Supreme Court would not preclude the court from giving a correct interpretation of the provisions. Counsel made reference to the decision of the Supreme Court in Salem Co-operative Central Bank Ltd. v. C.I.T. (201 ITR 697). 10. We may incidentally refer to the provision and the explanation to Section 127. 127. (1) The Director General or Chief Commissioner may, after giving the assessee a reasonable opportunity of being heard in the matter, wherever it is possible to do so, and after recording his reasons for doing so, transfer any case from one or more Assessing Officers subordinate to him (whether with or without concurrent jurisdiction) to any other Assessing Officer or Assessing Officers (whether with or without concurrent jurisdiction) also subordinate to him. (2) Where the Assessing Officer or Assessing Officers from whom the case is to be transferred and the Assessing Officer or Assessing Officers to whom the case is to be transferred are not subordinate to the same Director General or Chief Commissioner or Commissioner,- (a)where the Directors General or Chief Commissioners or Commissioners to whom such Assessing Officers are subordinate are in agreement, then the Director General or Chief Commissioner or Commissioner from whose jurisdiction the case is to be transferred may, after giving the assessee a reasonable opportunity of being heard in the matter, wherever it is possible to do so, and after recording his reasons for dong so, pass the order; (b) where the Directors General or Chief Commissioner or Commissioners aforesaid are not in agreement, the order transferring the case may, similarly, be passed by the Board or any such Director General or Chief Commissioner or Commissioner as the Board may, by notification in the official Gazette, authorize in this behalf. (3) Nothing in sub-section (1) or sub-section (2) shall be deemed to require any such opportunity to be given where the transfer is from any Assessing Officer or Assessing Officers (whether with or without concurrent jurisdiction) to any other Assessing Officer or Assessing Officer (whether with or without concurrent jurisdiction) and the offices of all such offices are situated in the same city, locality or place. (4) The transfer of a case under sub-section (1) or sub-section (2) may be made at any stage of the proceedings, and shall not render necessary the re-issue of any notice already issued by the Assessing Officer or Assessing Officers from whom the case is transferred. Explanation:- In section 120 and this section, the word “case” in relation to any person whose name is specified in any order or direction issued there under, means all proceedings under this Act in respect of any year which maybe pending on the date of such order or direction or which may have been completed on or before such date, and includes also all proceedings under this Act which may be commenced after the date of such order or direction in respect of any year. Section 127 confers powers on the Director of Chief Commissioner of Income Tax to transfer any case from one or more Assessing Officers subordinate to him to any other Assessing Officer, after giving the assessee a reasonable opportunity of being heard in the matter, wherever it is possible to do so, and after recording his reasons for doing so. Section 127 therefore confers power to transfer cases. Section 120, on the other hand, deals with jurisdiction of income tax authorities, which says that income Tax authorities shall exercise all or any of the powers and perform all or any of the functions conferred on, or as the case may be, assigned to such authorities by or under this Act in accordance with such directions as the Board may issue for the exercise of the powers and performance of the functions by all or any of those authorities. Section 124 deals with jurisdiction of assessing officers, which says where by virtue of any direction or order issued under sub-section (1) or sub-section (2) of section 120, the assessing officer has been vested with jurisdiction over any area, within the limits of such area, he shall have jurisdiction in respect of any person carrying on a business or profession, if the place at which he carried on his business or profession is situate within the area, or where his business or profession is carried on in more places than one, if the principal place of his business or profession is situate within the area, etc. Therefore Sections 120 and 124 deal with jurisdiction and Section 127 deals with power. Therefore Sections 120 and 124 deal with jurisdiction and Section 127 deals with power. Jurisdiction does not mean power to do or order the act impugned but generally the authority of an officer to act in the matter. Power means authority to give one to another to act for him or to do some specified acts. The expression “power” is not always synonymous with jurisdiction. Section 120 uses the expression “jurisdiction” and section 127 uses the expression “power” having different meaning and content. While exercising the powers under Section 127 the Chief Commissioner is not exercising any jurisdiction but exercising power of transferring a case from one officer to another. Section 158 BG also confers powers on the Assistant Commissioner or Deputy Commissioner, as the case may be, to make block assessment. In other words, jurisdiction to make block assessment has been conferred to the Assistant Commissioner or to the Deputy Commissioner by the statute. Chief Commissioner has only transferred the case from one officer to another officer. 11. Power under section 127 has to be exercised in public interest and in the best interest so as to facilitate effective and co-ordinated investigation. Section 127 gives sufficient procedure to the assessee including an opportunity of being heard wherever it is possible. Chief Commissioner in exercise of the power conferred under section 127 has also to record reasons. Admittedly statutory formalities have already been complied with in the instant case, but question posed is whether block assessment would fall in the explanation to Section 127 and whether the Commissioner has got the power to transfer the case of the assessee. Section 127 has used the expression “any case”. Explanation contains the word “case” in relation to any person whose name is specified in any order or direction issued there under, means all proceedings under the Income Tax Act in respect of any year. Therefore, the expression “any case” means all proceedings under the Act in respect of any year. The expression “any year” and “any case” exclude limitation or qualification, which points in a distributive construction. The words “any case” and “any year” connote wider generality. The word “any” may have one of several meanings according to the circumstances it may mean “all”, “each”, “every”, “some”, or one or more out of several. The expression “any year” and “any case” exclude limitation or qualification, which points in a distributive construction. The words “any case” and “any year” connote wider generality. The word “any” may have one of several meanings according to the circumstances it may mean “all”, “each”, “every”, “some”, or one or more out of several. In Gangadhar Narasingdas Agarwal v. Union of India (1967 (1) MLJ 197) it was held that the word “any” means all except where this wide construction is limited by subject matter and context of a particular statute. In Ashiq Hassan Khan v. S.D.O. (AIR 1965 Patna 444) and Chandi Prasad v. Rameshwar Prasad (AIR 1967 Patna 41) it was held that the expression given to the word “any” in certain context and subject matter excludes limitation or qualification. Considering the object and purpose of Section 127 and to facilitate effective and co-ordinate investigation, the explanation to Section 127 has to be liberally construed and therefore “block assessment” would fall within the expression “case” enabling the Commissioner to transfer those cases relating to block assessment to the subordinate officer. Section 127 is also a provision and the courts would lean in favour of an interpretation which makes the provision workable. Ut res valeat polius quar pareat, a construction be put upon the provision so as to uphold them and carry into effect the intention. That cannot be interpreted in a restrictive manner and making the machinery unworkable. Machinery section should always be construed so as to effectuate and charging rule is that construction should be workable. Reference was made to the decisions in 48 ITR 442, 32 ITR 289, Bhimraj Pannalal v. CIT (41 ITR 221). Looking at the question in the above perspective, we find no infirmity in the order passed by the Chief Commissioner in transferring the case to the assistant Commissioner of Income Tax, Calicut. We therefore answer the question in favour of the Revenue and dismiss the appeal and writ petition.