Section 124 Deals with Territorial Jurisdiction, Not Core Jurisdictional Conditions of Section 153C: Bombay HC

Peter Vaz Vs CIT (Bombay High Court)

The Bombay High Court addressed appeals concerning the applicability of Section 2(22)(e) and 153C of the Income Tax Act. Peter Vaz, represented by legal heirs, challenged the ITAT’s decision, which upheld the Assessing Officer’s order treating loans as deemed dividends. The court framed an additional substantial question of law regarding the assessee’s right to challenge the jurisdiction under Section 153C without filing cross-objections. The court noted that a search under Section 132 was conducted on the firm and company, not dir

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