Territorial jurisdiction in writ challenges depends on the assessing authority, not the locations of related transactions.

Territorial jurisdiction for a writ challenge to an assessment order depends on the authority that passed the order, not on the locations of related transactions. The impugned assessment was made by the ETO-cum-Proper Officer at Chandigarh on a return filed there, so the proper challenge lay before the forum having appellate or supervisory jurisdiction over that authority. The fact that some transactions involved Patna, Delhi and Chandigarh did not by itself confer jurisdiction on the Patna HC. The writ petition was therefore held not maintainable before the Patna HC and was dismissed as not entertained.

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Issues: Whether the writ petition was maintainable before the Patna High Court in relation to an assessment order passed by the proper officer at Chandigarh.

Analysis: The impugned order was passed by the ETO-cum-Proper Officer at Chandigarh on the petitioner's return filed there. The Court held that the challenge to that order lay before the competent forum having appellate or supervisory jurisdiction over that authority, and that the mere fact that some underlying transactions involved locations at Patna, Delhi and Chandigarh did not confer territorial jurisdiction on the Patna High Court.

Conclusion: The writ petition was not maintainable before the Patna High Court and was dismissed as not entertained.

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