Territorial jurisdiction in income-tax appeals may follow the place where the Tribunal passed the impugned order.

Territorial jurisdiction for income-tax appeals may be determined by the place where the impugned appellate order is made, because an appeal can be treated as an extension of the original suit for forum and venue purposes. Applying civil procedure principles on place of suing, jurisdiction follows the place where the cause of action arises wholly or in part. Since the Tribunal's orders were passed within the High Court's territorial limits, the cause of action arose there and the High Court had territorial jurisdiction to entertain the appeals. The appeals were therefore maintainable on jurisdictional grounds, although they ultimately failed and were dismissed on the substantive issues already decided earlier.

---

---

Issues: Whether the High Court had territorial jurisdiction to entertain the income-tax appeals where the impugned orders were passed by the Tribunal within its territorial limits.

Analysis: The appeal was treated as an extension of a suit for the purpose of determining forum and venue. The principles embodied in the Code of Civil Procedure governing place of suing were applied, particularly the rule that jurisdiction follows the place where the cause of action, wholly or in part, arises. As the impugned orders were those of the Tribunal and were passed within the territorial jurisdiction of the High Court, the cause of action was held to arise within that jurisdiction.

Conclusion: The High Court had territorial jurisdiction to decide the appeals.

Final Conclusion: The appeals were held to be maintainable before the High Court on jurisdictional grounds, but they ultimately failed and stood dismissed in line with the earlier decision on the same substantial questions of law.

Ratio Decidendi: In an appeal, jurisdiction may be founded on the territorial location where the impugned appellate order was passed, since the cause of action for the appeal arises where that order is made.

---