Territorial jurisdiction objections under income tax law must be raised promptly under the statutory procedure or they cannot be revived in appeal.

Section 124 of the Income-tax Act, 1961 requires an assessee to challenge the place of assessment or territorial jurisdiction of the assessing officer at the earliest stage and within the prescribed time and manner. A territorial objection is treated as a procedural jurisdiction challenge, not as an inherent lack of jurisdiction, so it cannot be raised later in appeal if the statutory procedure was not followed. The appellate machinery cannot be used to bypass the specific objection mechanism in section 124, and such objections must be decided at the inception of assessment proceedings.

---

---

Issues: Whether an objection to the place of assessment or the territorial jurisdiction of the Income-tax Officer could be raised before the appellate authority when no such objection was raised before the Income-tax Officer within the time and manner prescribed by section 124 of the Income-tax Act, 1961.

Analysis: Section 124 of the Income-tax Act, 1961 creates a self-contained procedure for challenging the jurisdiction of the assessing officer. Sub-sections (5) and (6) require the assessee to raise the objection at the earliest stage and within the prescribed time, failing which the objection cannot be entertained later in appeal. A territorial objection is not treated as a case of inherent lack of jurisdiction, and the statutory machinery cannot be bypassed by resorting to the general appeal provisions. The principle that jurisdictional objections relating to venue or place of assessment must be taken promptly was reinforced by the scheme of the Act and by general procedural principles requiring such objections to be decided at the inception.

Conclusion: The objection was not entertainable at the appellate stage and was held to be barred by section 124; the answer was against the assessee and in favour of the Revenue.

Ratio Decidendi: An objection to the territorial jurisdiction or place of assessment under the Income-tax Act, 1961 must be raised within the statutory time and procedure prescribed by section 124, and if not so raised it cannot be entertained later in appeal.

---