Jurisdiction under work allocation among Commissioners (Appeals) invalidated the order and led to remand for fresh adjudication.

Allocation of work among Commissioners (Appeals) determines which appellate authority can validly hear and decide a matter; an order passed by an officer without such jurisdiction is legally unsustainable. The impugned order was found to have been made after the work allocation had taken effect, so the deciding Commissioner (Appeals) lacked jurisdiction. That jurisdictional defect went to the root of the decision, requiring the order to be set aside and the matter remanded to the jurisdictional Commissioner (Appeals) for fresh consideration.

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Issues: Whether the Commissioner (Appeals) had jurisdiction to pass the impugned order after the allocation of work among Commissioners (Appeals), and whether the order was liable to be set aside and remanded.

Analysis: The impugned order was passed after the order allocating work among different Commissioners (Appeals). In view of that allocation, the authority who passed the order lacked jurisdiction to decide the matter. The jurisdictional defect went to the root of the decision and required interference.

Conclusion: The impugned order was jurisdiction and was set aside. The matter was remanded to the jurisdictional Commissioner (Appeals) for fresh .

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