2025 (2) TMI 1685

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....ng order of assessment passed u/s 143(3) r.w.s. 263/144B of the Act by National Faceless e-Assessment Centre, Delhi ['Ld. NFeAC' hereinafter] in relation to assessment year 2017-18 & 2020-21 ['AYs' hereinafter] respectively. 2. It emerges at the very outset upon conjoint consideration of records and submission of Ld. AR that; although the original assessments in these cases were framed in faceless regime, the assessing officer who holds the jurisdictional for passing order giving effect is indeed the Income Tax Officer, Ward-1, Sirsi of Uttara Kannada District of Karnataka ['Ld. AO' hereafter]. It is therefore brought to our notice that, the situs of the Ld. AO who exercises territorial jurisdiction over the assessee falls outside the te....

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....planation 4 to Standing Order dt. 01/10/1997 issued under rule 4(1) of Income Tax Appellate Tribunal Rules, 1963 categorically prescribes that; the ordinary jurisdiction of the Tribunal should be based on the location of the Jurisdictional Assessing Officer. Reinforcing the above principle, the Hon'ble Supreme court by its judgement in 'PCIT Vs ABC Papers Ltd.' (supra), has put the issue of jurisdiction of appellate forum to rest by holding that, the 'situs of the assessing officer' is the only decisive key factor for determining the jurisdiction of appellate forum irrespective of any administrative order passed u/s 127 of the Act in relation to transfer of cases. 6. In aforestated context we note that, the Hon'ble President of ITA....