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Jurisdiction of the Income Tax Officer at Nellore to pass valid assessment orders for the relevant assessment years under consideration. Detailed Analysis: The judgment involved a case where an assessee, a resident of Nellore, was assessed under the Income Tax Act for various assessment years. The assessment orders were challenged in appeal, and the issue of jurisdiction of the Income Tax Officer at Nellore was raised. The main question was whether an objection regarding the place of assessment could be raised before the appellate authority when not raised before the assessing officer initially. The court delved into the provisions of Section 124 of the Income Tax Act, which deals with the jurisdiction of the Income Tax Officer. The section lays down specific timelines and procedures for challenging the jurisdiction of the assessing authority. It was noted that objections to jurisdiction must be raised at the beginning of the assessment process, as per the scheme of the Act. Reference was made to previous judgments and legal principles to support the interpretation of the law. The court highlighted that objections based on territory should be decided at the earliest opportunity, following the principles of natural justice. The court emphasized the importance of addressing jurisdictional issues promptly to avoid wastage of time and resources for both the assessee and the revenue authorities. The judgment also discussed the application of specific clauses of Section 124(5) of the Act in the context of the case. The court concluded that the objections raised by the assessee regarding jurisdiction were belated and not maintainable at later stages of the proceedings under the Act. In light of the above analysis, the court answered the question referred against the assessee, indicating that the jurisdiction of the Income Tax Officer at Nellore to pass assessment orders for the relevant years was valid. No costs were awarded, and an advocate's fee was specified.
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