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The HC held that the respondent failed to establish how PAN-based jurisdiction reflected in the ITBA system conferred authority absent a statutory transfer order under s.127; a system migration error cannot supplant an express transfer order dated 25.10.2016. Admitting the technical non-migration, the respondent had accordingly assumed jurisdiction solely on system records. The court ruled that electronic records do not override statutory orders, quashed and set aside the impugned notice dated 30.03.2021 and the order disposing of objections for want of jurisdiction, and confirmed that jurisdiction has remained with the ITO at Bhavnagar since 25.10.2016. The ITO at Bhavnagar may, subject to time-bar constraints, exercise jurisdiction in accordance with law.
The HC held that the respondent failed to establish how PAN-based jurisdiction reflected in the ITBA system conferred authority absent a statutory transfer order under s.127; a system migration error cannot supplant an express transfer order dated 25.10.2016. Admitting the technical non-migration, the respondent had accordingly assumed jurisdiction solely on system records. The court ruled that electronic records do not override statutory orders, quashed and set aside the impugned notice dated 30.03.2021 and the order disposing of objections for want of jurisdiction, and confirmed that jurisdiction has remained with the ITO at Bhavnagar since 25.10.2016. The ITO at Bhavnagar may, subject to time-bar constraints, exercise jurisdiction in accordance with law.
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