Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
Helicopter charter classification requires effective control analysis, while territorial performance, reasoned credit orders and wilful suppression de...
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Territorial jurisdiction of the Assessing Officer must be exercised strictly in accordance with the jurisdictional directions and notifications issued under section 120, and concurrent jurisdiction arises only where specifically conferred. On the facts, the assessee's business and return particulars were at Kolkata, no Patna branch was shown, and the PAN tagging to Patna was found to be an error; the notice issued by the Patna officer was therefore without jurisdiction. The Tribunal held that the notice under section 143(2) and the consequential assessments were void, and the appeals were allowed with the assessment orders quashed.
Territorial jurisdiction of the Assessing Officer must be exercised strictly in accordance with the jurisdictional directions and notifications issued under section 120, and concurrent jurisdiction arises only where specifically conferred. On the facts, the assessee's business and return particulars were at Kolkata, no Patna branch was shown, and the PAN tagging to Patna was found to be an error; the notice issued by the Patna officer was therefore without jurisdiction. The Tribunal held that the notice under section 143(2) and the consequential assessments were void, and the appeals were allowed with the assessment orders quashed.
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