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Jurisdiction to entertain petitioner’s Revision application u/s 264 - The Court referenced Section 143(1)(A) and Section 120 of the Income Tax Act, emphasizing that CPC functions as a facilitator to the JAO, who maintains jurisdiction over the assessment process, including demand enforcement and assessment framing. - The Court highlighted the CBDT directive stating that powers under Sections 263 and 264 of the Act are to be exercised by the Jurisdictional Principal Commissioners of Income Tax, affirming the JAO's jurisdictional authority. - Despite initial uncertainty expressed by PCIT– 5 regarding jurisdiction, the Court directed him to exercise jurisdiction upon court order, clarifying that his hesitation should not be construed as a reluctance to perform his duties.
Jurisdiction to entertain petitioner’s Revision application u/s 264 - The Court referenced Section 143(1)(A) and Section 120 of the Income Tax Act, emphasizing that CPC functions as a facilitator to the JAO, who maintains jurisdiction over the assessment process, including demand enforcement and assessment framing. - The Court highlighted the CBDT directive stating that powers under Sections 263 and 264 of the Act are to be exercised by the Jurisdictional Principal Commissioners of Income Tax, affirming the JAO's jurisdictional authority. - Despite initial uncertainty expressed by PCIT– 5 regarding jurisdiction, the Court directed him to exercise jurisdiction upon court order, clarifying that his hesitation should not be construed as a reluctance to perform his duties.
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