Pecuniary jurisdiction for TDS refund claims limited the officer's power, making the rejection unsustainable and remittable.

The HC held that the Assessing Officer (TDS) lacked pecuniary jurisdiction to reject the refund claim because CBDT Circular No. 9/2015 assigned delayed refund claims to higher authorities according to monetary thresholds, with claims beyond the highest limit to be decided by the Board. The impugned rejection was therefore without jurisdiction and could not stand. The refund matter was remitted to the CBDT for fresh decision in accordance with law, and the petitioner succeeded.

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Issues: Whether the Assistant Commissioner of Income Tax (TDS) had jurisdiction to reject the petitioner's refund claim for tax deducted at source, and whether the impugned rejection could stand in view of the governing circulars and the prescribed pecuniary limits.

Analysis: The refund claim arose out of a TDS deposit made in the context of a survey and the later request for refund was considered against the framework of the CBDT instructions governing delayed refund claims. The Court noted that Circular No. 9/2015 superseded earlier instructions and fixed monetary limits for decision-making authority: claims up to a specified amount were to be dealt with by the Principal Commissioners/Commissioners, higher claims by the Principal Chief Commissioners/Chief Commissioners, and claims beyond the highest threshold by the Board. On that basis, the Court held that the Assessing Officer (TDS) who passed the impugned rejection had no pecuniary jurisdiction to decide the matter. The forwarding letter from the office at New Delhi was also treated as consistent with the matter requiring consideration by the competent higher authority.

Conclusion: The impugned rejection was without jurisdiction and could not be sustained. The refund matter was remitted to the Central Board of Direct Taxes for fresh decision in accordance with law, and the petitioner succeeded.

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