Statewide jurisdiction for Intelligence Officers can validly support section 45A proceedings against dealers across the State.

Statewide jurisdiction conferred on an Intelligence Officer by notification can validly support initiation of proceedings under section 45A of the Kerala General Sales Tax Act against dealers anywhere in the State. Section 3(2) permits the Government to appoint officers and assign local limits, but that territorial restriction governs the area of performance and does not prevent a broader jurisdiction where the statutory scheme authorises it. Section 45A proceedings are distinct from assessment proceedings, so they are not confined by the local jurisdiction applicable to assessment. The contrary view was overruled, and the petitions were dismissed.

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Issues: Whether an Intelligence Officer notified by the Government with statewide jurisdiction can validly initiate proceedings under section 45A of the Kerala General Sales Tax Act against a dealer anywhere in the State, and whether such action is invalid merely because the officer is not confined to local limits.

Analysis: Section 3(2) permits the Government to appoint officers for the functions assigned under the Act and to assign local limits for their performance. The restriction in the provision operates on the territorial area within which an appointed officer functions, but it does not limit the Government's power to confer statewide jurisdiction where the statutory scheme so permits. Proceedings under section 45A are distinct from assessment proceedings and are not controlled by the local jurisdiction applicable to assessment. Officers notified as assessing authorities under the Act are competent to initiate section 45A action, and such initiation is not without jurisdiction merely because the officer acts throughout the State.

Conclusion: An Intelligence Officer conferred with statewide jurisdiction by notification can initiate proceedings under section 45A against dealers anywhere in the State, and the contrary view was overruled. The petitions were dismissed.

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