Pan-India service-tax jurisdiction remains valid where notification framework empowers investigating officers, while pre-consultation guidance cannot invalidate notices.

Pan-India jurisdiction of specified Central Excise Officers for service-tax investigations and show-cause notices was validly conferred through Notification No. 22/2014-Service Tax read with the existing notification framework. The reference to "local limits" did not prevent all-India allocation of powers, and the existence of multiple empowered officers did not undermine jurisdiction. The departmental pre-consultation requirement in the Master Circular was recommendatory and could not override the governing statute; its non-observance did not invalidate show-cause notices. Challenges to factual matters in orders-in-original must be pursued through the statutory appellate remedy.

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Issues: (i) Whether Notification No. 22/2014-Service Tax validly conferred pan-India jurisdiction on specified Central Excise Officers for service-tax investigations and issuance of show-cause notices; (ii) Whether non-compliance with the departmental pre-consultation circular invalidated the show-cause notices.

Issue (i): Whether Notification No. 22/2014-Service Tax validly conferred pan-India jurisdiction on specified Central Excise Officers for service-tax investigations and issuance of show-cause notices.

Analysis: Section 2(b) of the Central Excise Act, 1944, Rule 3 of the Central Excise Rules, 2002, Rule 3 of the Service Tax Rules, 1994, and the relevant notifications authorised the Board to appoint and invest Central Excise Officers with powers under Chapter V of the Finance Act, 1994. The expression "local limits" did not prohibit assignment of all-India jurisdiction. Notification No. 22/2014-Service Tax was read with the pre-existing Notification No. 38/2001-C.E. (N.T.), which had vested the concerned intelligence officers with pan-India authority. Plurality of empowered officers did not invalidate the notification or offend comity of jurisdiction.

Conclusion: Notification No. 22/2014-Service Tax validly conferred pan-India jurisdiction, and show-cause notices issued by officers outside the taxpayer's local zone were valid. The finding is against the assessee.

Issue (ii): Whether non-compliance with the departmental pre-consultation circular invalidated the show-cause notices.

Analysis: The pre-consultation requirement in the Master Circular was recommendatory and could not prevail over the governing statute. Non-observance of that departmental guidance did not furnish a basis to quash a show-cause notice.

Conclusion: Non-compliance with pre-consultation did not invalidate the show-cause notices. The finding is against the assessee.

Final Conclusion: The notification, investigation, and show-cause process remained legally sustainable; challenges to factual matters arising from orders-in-original must be pursued through the statutory appellate remedy.

Ratio Decidendi: A statutory power to assign officers within "local limits" permits the Board to confer pan-India jurisdiction where the applicable legislative scheme and notifications so provide, and a recommendatory departmental circular cannot override that statutory authority.

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