Harish Kumar Chhabada v. PCIT [2025] 179 taxmann.com 589 / (2026) 349 CTR 42 (Chhattisgarh)(HC)

S. 124: Jurisdiction of Assessing Officer-The jurisdictional Assessing Officer is justified in processing the return of income filed by the assessee based on his PAN database residential address. The assessee cannot challenge the jurisdiction of the AO before the Tribunal in view of the limitation period prescribed under section 124(3)(a)-Assessee did not update current address in PAN database, and notices for scrutiny were issued and served at PAN address; said service was valid and constituted proper service. [S. 124(3)(a), 143(2)]

The AO, Ward 1(2), Raipur issued notice under section 143(2), and the AO, Ward 2(1), Raipur passed an assessment order under section 143(3) on a notification issued pursuant to territorial reallocation of wards at Raipur. The addition made by the AO, Ward 2(1), Raipur was confirmed by the CIT(A). Before the Tribunal, the assessee challenged CIT(A)’s order and also the jurisdiction of the AO, as it was based on the residential address and on the basis of his business address. The Tribunal confirmed the addition and dismissed the jurisdictional ground in view of the provisions of section 124(3)(a). The High Court confirmed the order passed by the Tribunal as the assessee had not made any application for change in address to the concerned AO and therefore the jurisdictional AO was justified in processing the return of income filed by the assessee based on his PAN database residential address. The High Court also held that the plea with regard to territorial jurisdiction of the ITO was barred by virtue of Section 124(3)(a) of the IT Act. Court also held that  the  assessee did not update the current address in PAN database, and notices for scrutiny were issued and served at PAN address; said service was valid and constituted proper service.(AY. 2012-13)

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