Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Territorial jurisdiction under Article 226 depends on whether the material, essential and integral cause of action arises within the forum, and the doctrine of forum conveniens may justify refusal even if some connection with Delhi exists. The Court held that the petitioners' residence, the searches and seizures, the ECIR, the investigating officers, and the PMLA proceedings were all centred in Gurugram, so Delhi was not the appropriate forum. It further held that the respondent-authority's location or the mere registration of the predicate offence in Delhi did not confer jurisdiction, because money-laundering is an independent offence. The writ petition was dismissed, with liberty to approach the jurisdictional High Court.
Territorial jurisdiction under Article 226 depends on whether the material, essential and integral cause of action arises within the forum, and the doctrine of forum conveniens may justify refusal even if some connection with Delhi exists. The Court held that the petitioners' residence, the searches and seizures, the ECIR, the investigating officers, and the PMLA proceedings were all centred in Gurugram, so Delhi was not the appropriate forum. It further held that the respondent-authority's location or the mere registration of the predicate offence in Delhi did not confer jurisdiction, because money-laundering is an independent offence. The writ petition was dismissed, with liberty to approach the jurisdictional High Court.
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