https://www.taxtmi.com/caselaws?id=6376 A quasi-judicial authority cannot finally determine its own jurisdiction by wrongly deciding a jurisdictional fact such as the recipient's residence; where liability to deduct tax depends on the payee being a non-resident, that foundational issue remains open to challenge, including in writ proceedings. The appellate remedy under section 30(1A) of the Income-tax Act, 1922 was held inapplicable where the assessee disputed the very basis of liability and contended that no deduction was required because the payee was not a non-resident firm. The appeal therefore succeeded, the High Court Appellate Bench order was set aside, and the matter was remitted for fresh decision with all contentions left open. en-us Fri, 22 Sep 1972 00:00:00 +0530 Tue, 13 Jan 2026 17:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6376 A quasi-judicial authority cannot finally determine its own jurisdiction by wrongly deciding a jurisdictional fact such as the recipient's residence; where liability to deduct tax depends on the payee being a non-resident, that foundational issue remains open to challenge, including in writ proceedings. The appellate remedy under section 30(1A) of the Income-tax Act, 1922 was held inapplicable where the assessee disputed the very basis of liability and contended that no deduction was required because the payee was not a non-resident firm. The appeal therefore succeeded, the High Court Appellate Bench order was set aside, and the matter was remitted for fresh decision with all contentions left open. Case-Laws Income Tax Fri, 22 Sep 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6376