Territorial jurisdiction for tax prosecution turns on where the false statement is delivered, not where assessment later occurs.

Territorial jurisdiction for complaints under sections 277 and 278 of the Income-tax Act turns on where the offence is committed: a false statement is complete when delivered, and abetment is complete when made. Applying section 177 of the Criminal Procedure Code, the complaint was triable at the place where the false estimates were delivered and the alleged abetment occurred, not where later assessment or penalty proceedings were conducted. The completion of proceedings elsewhere did not shift the place of commission, and convenience could not displace the territorial rule.

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Issues: Whether the Delhi courts had territorial jurisdiction to try the complaint alleging offences under section 277 and section 278 of the Income-tax Act, 1961, read with the Indian Penal Code, when the false estimates were delivered at Kanpur.

Analysis: The offence under section 277 is complete when the false account or statement is delivered, and the offence under section 278 is complete when the abetment is made. Applying section 177 of the Criminal Procedure Code, every offence is ordinarily triable by the court within whose local jurisdiction it was committed. Since the impugned estimates were delivered at Kanpur and the alleged abetment also took place there, the offences were committed at Kanpur. The completion of assessment or penalty proceedings at Delhi did not determine the place of commission of the offences, and convenience could not override the territorial rule.

Conclusion: The Delhi courts had no jurisdiction to try the complaint, and the impugned order was liable to be quashed.

Final Conclusion: The complaint was transferred to the Chief Judicial Magistrate, Kanpur, for decision in accordance with law.

Ratio Decidendi: An offence under section 277 or section 278 of the Income-tax Act, 1961 is triable at the place where the false statement is delivered or the abetment occurs, and not at the place where assessment or penalty proceedings are later taken.

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