Territorial assessment jurisdiction depends on statutory allocation, not on who issued the notice, and another competent officer may complete assessment.

Assessment jurisdiction remained territorial and depended on the Commissioner's allocation of work among competent assessing authorities. Service of notice in form S.T. XIV did not itself confer exclusive jurisdiction on the officer who issued it, and the dealer could not insist that only that officer conclude the assessment. Where another duly empowered territorial assessing authority actually conducted and completed the proceedings, the assessment was valid. On the stated facts, Shri R.C. Minocha was competent to pass the assessment order, and the contrary finding on jurisdiction was incorrect.

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Issues: Whether Shri R.C. Minocha was competent to pass the assessment order despite notice under form S.T. XIV having been issued earlier by another Sales Tax Officer.

Analysis: Under the Act and the Rules, assessment jurisdiction was territory-based and flowed from the Commissioner's power to appoint and distribute work among assessing authorities. The service of notice in form S.T. XIV was only part of the procedure and did not itself confer exclusive jurisdiction on the officer who issued it. Where more than one officer had territorial jurisdiction, either could act, but the dealer could not insist that only the officer who issued the notice must conclude the assessment. On the record, Shri Gupta took no effective further steps after issuing the notice, while the proceedings were actually conducted and concluded by Shri Minocha, who had been appointed as assessing authority for the whole Union Territory of Delhi.

Conclusion: Shri R.C. Minocha was competent to pass the assessment order, and the finding that he lacked jurisdiction was incorrect.

Final Conclusion: The reference was answered in favour of the Revenue, and the assessment was upheld.

Ratio Decidendi: A notice issued in assessment proceedings does not by itself create exclusive jurisdiction, and an assessment is valid when made by another competent territorial assessing authority who was duly empowered to act and who actually conducted the proceedings.

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