Territorial jurisdiction under income-tax law prevails over administrative monetary allocation of work.

Jurisdiction under the Income-tax Act depends on territorial area and directions or orders under section 120, and more than one Assessing Officer may have concurrent authority where the statutory scheme permits. Monetary allocation of work between officers is only an administrative arrangement and does not by itself negate jurisdiction if the officer otherwise has territorial jurisdiction over the assessee. Because the assessee admitted the issuing officer's territorial jurisdiction, the challenge based solely on pecuniary assignment failed, and the section 148 notice and rejection of objection were treated as valid.

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Issues: Whether the notice under section 148 of the Income-tax Act, 1961 and the order rejecting the objection were without jurisdiction on the ground that the Income-tax Officer, though having territorial jurisdiction, was not the officer to whom the monetary limit for the case was assigned.

Analysis: The statutory scheme of sections 2(7A), 120 and 124 of the Income-tax Act, 1961 shows that an Assessing Officer is vested with jurisdiction by directions or orders issued under section 120, and that jurisdiction is linked to territorial area as well as the directions of the Board and the competent administrative orders. The provisions also recognise that more than one Assessing Officer may have concurrent authority in appropriate circumstances. The monetary allocation of work between officers is an administrative arrangement and does not, by itself, create an inherent lack of jurisdiction where the officer otherwise has territorial jurisdiction over the assessee. Since the petitioner admitted the territorial jurisdiction of the officer who issued the notice, the challenge based only on pecuniary assignment could not succeed.

Conclusion: The jurisdictional challenge failed, and the notice under section 148 and the order rejecting objection were held to be valid.

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