Territorial jurisdiction under section 120 failed where the Patna Assessing Officer was not vested to issue notice or complete assessment.

Territorial jurisdiction under section 120 depended on the Board's allocation framework, and the assessee's business address, PAN particulars and return details showed Kolkata as the jurisdictional location. On those facts, the Patna Assessing Officer was not shown to have territorial jurisdiction to issue notice under section 143(2) or complete the assessments. The notices and assessment orders issued from Patna were therefore without jurisdiction and were quashed in favour of the assessee.

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Issues: Whether the Assessing Officer at Patna had territorial jurisdiction to issue notice under section 143(2) and complete the assessments for the assessment years 2014-15 and 2015-16.

Analysis: The Assessee's business, PAN address, returns of income, and other registration details all showed Kolkata as the place of business and jurisdictional location. The statutory scheme under section 120 of the Income-tax Act, 1961 permits exercise of powers only in accordance with Board directions and notifications, including allocation based on territorial area and other jurisdictional criteria. On the facts found, the Patna Assessing Officer was not shown to have been vested with territorial jurisdiction over the Assessee, and the notices and assessment orders issued from Patna were contrary to the jurisdictional notification framework.

Conclusion: The notices under section 143(2) and the assessment orders passed by the Patna Assessing Officer were without jurisdiction and were quashed; the issue is decided in favour of the Assessee.

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