AO has no jurisdiction to examine constitutional validity of any Act

Assessing officer being a statutory authority under the Act is bound to respect all the laws may be made by the Parliament or may be made by the State Legislature. He has no jurisdiction to examine the constitutional validity of any Act or the statute or a subordinate legislation which creates statutory liability upon the assessee to make the payment by way of an expenditure incurred.

Assessing officer has no authority or competence to hold that the privilege fee is not having the character of statutory fee or that the State L

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