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Issues:
1. Challenge of jurisdiction by petitioners beyond the allowed time limit. 2. Interpretation of time limit for challenging jurisdiction under the Income-tax Act. 3. Comparison of judgments regarding the computation of time for challenging jurisdiction. 4. Obligation of the Income-tax Officer to refer the question of limitation to the Commissioner. 5. Allegation of failure to observe the rules of natural justice by the Income-tax Officer. Analysis: 1. The petitioners challenged the jurisdiction of the Income-tax Officer beyond the prescribed time limit, leading to a dispute regarding the validity of the objection raised by them. The petitioners' letter questioning jurisdiction reached the Officer after the extended deadline, raising concerns about the timeliness of their challenge. 2. The interpretation of the time limit for challenging jurisdiction under the Income-tax Act was a crucial aspect of the case. The petitioners argued that the extended time for submitting their return also extended the period to question the Officer's jurisdiction. However, the Court emphasized that the objection must be communicated within the specified timeframe, regardless of any extensions granted for return submission. 3. A comparison of judgments from various High Courts regarding the computation of time for challenging jurisdiction was conducted. The Court disagreed with the Orissa High Court's approach and preferred the views of other High Courts, emphasizing the importance of timely communication of objections to the concerned authority. 4. The obligation of the Income-tax Officer to refer the question of limitation to the Commissioner was analyzed. It was clarified that the Officer is only required to refer the matter if he disagrees with the assessee's objection on merits. In cases where the objection is considered time-barred, there is no obligation to refer the issue for determination. 5. The petitioners alleged a failure to observe the rules of natural justice by the Income-tax Officer, claiming they were not given an opportunity to be heard before the decision on the limitation issue. The Court examined the provisions of the Income-tax Act and emphasized the importance of providing a hearing opportunity before determining questions on merits. In conclusion, the Court dismissed the petition, highlighting that even if there were procedural errors in the Income-tax Officer's decision, no prejudice was caused to the petitioners as they had the opportunity to present their arguments. The judgment underscored the significance of timely challenges to jurisdiction and adherence to procedural requirements in tax matters.
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