Territorial jurisdiction under income-tax law permits concurrent officers and validates assessments by authorised Additional Income-tax Officers.

Section 64 recognises territorial assessment by local Income-tax Officers and permits concurrent jurisdiction where business spans areas; a voluntary transfer of the assessment file for convenience does not create a disputed place of assessment requiring reference to the Commissioner, and an officer in a concurrent area may act on a valid notice issued under Sections 34 and 22(2) without issuing a fresh notice. An Additional Income-tax Officer authorised within the district may validly complete assessments within territorial authority. The Appellate Tribunal's refusal to state a case under Section 66(2) was upheld as correct; the transfers, notice and assessment were held valid and the challenge dismissed.

---

---

Issues: Whether the transfer of the income-tax file between Income-tax Officers and the notice issued under Sections 34 and 22(2) of the Income-tax Act were valid, and whether the subsequent assessment by the Additional Income-tax Officer was without jurisdiction.

Analysis: Section 64 establishes assessment by the Income-tax Officer for the area of the place of business and grants each local Income-tax Officer powers in respect of income arising within his area; where business is carried on in more than one area officers have concurrent territorial jurisdiction. A request by the assessee or his agent for transfer of the file for convenience does not raise a disputed question as to the place of assessment under sub-section (3) requiring reference to the Commissioner. Where one officer with concurrent jurisdiction issues a valid notice under Sections 34 and 22(2), another officer in a concurrent area may act upon that notice without issuing a fresh notice. The presence of an Additional Income-tax Officer authorised to exercise income-tax powers within the district validates assessments made by that officer acting within territorial authority. The Appellate Tribunal's refusal to state a case under Section 66(2) is not to be set aside where its decision is correct on the law.

Conclusion: The transfers of the file were valid; the notice issued under Sections 34 and 22(2) was valid; the Additional Income-tax Officer had jurisdiction to complete the assessment; the Appellate Tribunal's refusal to state a case was correct. The applicant's challenge is dismissed.

---