Territorial jurisdiction objection fails where belated challenge is barred and no prejudice from the assessment forum is shown.

An objection to the Assessing Officer's territorial jurisdiction failed because it was raised after notices had been issued and partly complied with, triggering the statutory bar on belated jurisdictional challenge. The assessment was valid where the return was filed before the officer having jurisdiction on the basis of the address stated in the return, the jurisdiction was not displaced, and the competent administrative authorities declined transfer during time-barring proceedings. The allocation of functions under the Income-tax Act was treated as procedural, and no prejudice or denial of justice was shown. The assessment and the appellate order sustaining it were upheld.

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Issues: Whether the assessment was without jurisdiction because the assessee objected to the Assessing Officer's territorial jurisdiction and sought transfer of the case to another jurisdiction.

Analysis: The assessment was held to be valid because the assessee filed the return with the officer who had jurisdiction on the basis of the address given in the return, and the jurisdiction was never successfully displaced. The objection to jurisdiction was raised belatedly, after notices had already been issued and partly complied with, attracting the bar on late objection under the jurisdictional provisions of the Income-tax Act. The matter was also considered by the Commissioner and the Chief Commissioner, who declined transfer during time-barring assessment proceedings. The allocation of functions under the Act was treated as procedural, and no prejudice or denial of justice was shown. The authorities relied on by the assessee were distinguished on facts.

Conclusion: The challenge to jurisdiction failed and the assessment was not invalid for want of jurisdiction.

Final Conclusion: The assessment order and the appellate order sustaining it were upheld, and the assessee's appeal failed on the jurisdictional ground.

Ratio Decidendi: An objection to the Assessing Officer's territorial jurisdiction must be raised within the period prescribed by the jurisdictional provisions, and where jurisdiction has been validly assigned and the objection is decided by the competent administrative authorities, the assessment is not vitiated merely because the assessee later disputes the forum.

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