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Supreme Court of India 2022-08-18

PR. COMMISSIONER OF INCOME TAX – I, CHANDIGARH vs M/S. ABC PAPERS LIMITED

Bench: 3 — Uday Umesh Lalit, S. Ravindra Bhat, Pamidighantam Sri Narasimha

In Brief

The Supreme Court resolved a critical issue regarding appellate jurisdiction under the Income Tax Act, 1961. When the ITAT exercises jurisdiction over multiple states, the question arose as to which High Court could hear appeals under Section 260A. The Court held that the High Court in whose territorial jurisdiction the original Assessing Officer (not the transferee officer) is located has jurisdiction. The Court overruled the Delhi High Court's contrary decisions in Sahara and Aar Bee, which had held that transfer orders under Section 127 shift jurisdiction to the transferee officer's High Court. The Court reasoned that transfer orders concern only administrative authority over Income Tax officials, not judicial remedies, and allowing executive orders to alter appellate jurisdiction would improperly subordinate judicial independence to executive power.", "disposition": "partly_allowed

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Income Tax Law Appellate Jurisdiction Administrative Law Tribunal Procedure High Court Jurisdiction Transfer of Cases Judicial Remedies Constitutional Law

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