TMI BlogSupreme Court Clarifies Jurisdictional Objections in Tax Assessments: A Landmark OrderX X X X Extracts X X X X X X X X Extracts X X X X ..... igh Court [ 2019 (3) TMI 1996 - ORISSA HIGH COURT] on grounds that the jurisdictional officer did not adjudicate upon the returns. Post the filing of returns, a change in jurisdiction occurred. Notably, despite the issuance of a notice under Section 142 (1), the assessee engaged in the proceedings without objecting to the assessing officer's jurisdiction. This aspect becomes pivotal, given tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tional requisites, highlighting the procedural oversight by the assessee. Engagement Post-Notice: The assessee's engagement after the issuance of the Section 142 (1) notice without challenging jurisdiction was deemed a tacit acceptance of such jurisdiction, thereby invalidating the grounds for the High Court's order. Remedial Direction: Despite overturning the High Court's judgment, th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e between legal proceduralism and substantive justice in tax law. Comparative Insight with Previous High Court Order [ 2019 (3) TMI 1996 - ORISSA HIGH COURT] The previous High Court decision in 2019 similarly grappled with jurisdictional issues in tax assessments. However, the High Court then focused on the validity of jurisdiction vested with the assessing authority, contrasting with the Supreme ..... X X X X Extracts X X X X X X X X Extracts X X X X
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