Case LawsIncome Tax
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Jurisdiction in tax assessments: improper issuing authority can invalidate notices and require reissuance by competent authority.
Jurisdiction in tax assessments was the pivotal issue: the record showed assessment power lay with the Commissioner of Income Tax (Exemption), not the subordinate officer who issued the contested notice, rendering that notice issued without jurisdiction. The petition also challenged adherence to principles of natural justice. The court refrained from adjudicating the substantive assessment and demand because those aspects were subject to statutory appeal, distinguishing jurisdictional defects from appealable merits and allowing issuance by the competent authority in conformity with procedural safeguards.