PCIT Chandigarh v. ABC Papers Limited
Finin2min Judgment Intelligence is provided for general informational and educational purposes only. It is not legal, tax, accounting, investment or other professional advice and is not a substitute for advice on the user's specific facts. The Finin2min summary, Q&A, reliance profile, fact-match indicators, comparisons and practical takeaways are editorial analysis and are not part of the Court/Tribunal judgment. Before citing, filing, advising or acting on a case, read the complete official judgment/order, verify the cause title, case number, coram, date, applicable statutory text and jurisdiction, and check subsequent appellate history, review/SLP status and later amendments. A similar fact pattern does not guarantee the same outcome. No advocate-client, CA-client or other professional relationship is created by use of this page.
Case in 2 minutes
PCIT Chandigarh Vs ABC Papers Limited (Supreme Court) Date-18th August 2022 Sub-The Hon’ble Supreme court in this case was called upon to decide which High Court would have the jurisdiction to entertain an appeal against a decision of a Bench of the ITAT exercising jurisdiction over more than one state, particularly when case(s) of same assessment year are transferred under Section 127 of the Act. Should it be the High Court of the State in which the ITAT is physically located or the High Court of the State in which the Assessee is residing and/or doing its business or the High Court where the Assessing Officer…
Result: Dismissed. The controlling text is the reasoning and operative order in the packaged judgment, not this editorial summary.
Case snapshot
Sections / provisions: 127 of the Income-tax Act; 1961
Questions before the Court / Tribunal
- PCIT Chandigarh Vs ABC Papers Limited (Supreme Court) Date-18th August 2022 Sub-The Hon’ble Supreme court in this case was called upon to decide which High Court would have the jurisdiction to entertain an appeal against a decision of a Bench of the ITAT exercising jurisdiction over more than one state, particularly when case(s) of same assessment year are transferred under Section 127 of the Act. Should it be the High Court of the State in which the ITAT is physically located or the High Court of the State in which the Assessee is residing and/or doing its business or the High Court where the Assessing Officer…
- What factual, statutory and procedural conditions control the relief?
- How does the operative order apply to the parties and the challenged proceeding?
Material facts and procedural background
PR. COMMISSIONER OF INCOME TAX – I, CHANDIGARH ...APPELLANT
4. The Appellant herein, M/s. ABC Papers Ltd.6 is a company engaged in the
Assessee filed its income tax returns before the Assessing Officer, New Delhi, on
assessment dated 30.12.2010. Aggrieved by that order, the Assessee preferred an
6 hereinafter referred to as ‘the Assessee’. Page 3 of 28
Appellant / assessee submissions
India, graciously consented to the learned counsel for the Assessee Sh. Rohit Jain
came up before the High Court of Delhi, it was contended that the High Court of
custody of the new Assessing Officer. It could be argued that the Assessing
Revenue / respondent submissions
The packaged judgment does not separately label the respondent's submissions in an independently extractable passage. No contention is inferred; read the full order.
Court / Tribunal analysis and reasoning
a different view. The Delhi High Court held that an administrative order of
Operative decision and relief
Punjab & Haryana which it disposed of by order dated 07.02.2019, against which
disposed of an appeal on 01.09.2017, against which an appeal was filed in the
High Court of Punjab & Haryana which it disposed of by order dated 07.02.2019,
said Civil Appeal is dismissed by upholding the order dated 07.02.2019 passed
Source and subsequent history
Primary record: Official primary source verified and packaged
Later-history status: Review / curative petition docket: check pending
Supreme Court review and curative docket closure has not yet been evidenced.
Ratio and legal principle
- The packaged judgment addresses PCIT Chandigarh Vs ABC Papers Limited (Supreme Court) Date-18th August 2022 Sub-The Hon’ble Supreme court in this case was called upon to decide which High Court would have the jurisdiction to entertain an appeal against a decision of a Bench of the ITAT exercising jurisdiction over more than one state, particularly when case(s) of same assessment year are transferred under Section 127 of the Act. Should it be the High Court of the State in which the ITAT is physically located or the High Court of the State in which the Assessee is residing and/or doing its business or the High Court where the Assessing Officer…. The precise proposition must be read with the Court/Tribunal's reasoning and operative directions.
- Reliance depends on matching the statutory version, jurisdiction, procedural stage and material evidence recorded in the judgment.
Why this judgment matters
This decision is relevant to practitioners and affected parties dealing with pcit chandigarh vs abc papers limited (supreme court) date-18th august 2022 sub-the hon’ble supreme court in this case was called upon to decide which high court would have the jurisdiction to entertain an appeal against a decision of a bench of the itat exercising jurisdiction over more than one state, particularly when case(s) of same assessment year are transferred under section 127 of the act. should it be the high court of the state in which the itat is physically located or the high court of the state in which the assessee is residing and/or doing its business or the high court where the assessing officer… Its value lies in showing how the adjudicating forum connected the applicable rule to the proved facts and procedural posture.
Practitioner action points
- Match the statutory version, jurisdiction, procedural stage and decisive evidence before relying on the result.
- Verify current appellate, review and SLP history and any later amendment or controlling authority.
- Attach the complete judgment to the working paper or filing and cite the paragraph/page supporting the proposition.
Can I rely on this judgment?
| Authority level | Supreme Court |
|---|---|
| Source integrity | Sanitized mirror generated from the verified official Supreme Court PDF |
| Repository release | Published |
| Reliance rule | Verify current history and cite the judgment's narrow proposition, not the editorial headnote. |
Does this case match your facts?
Stronger match when
- The same primary issue is raised.
- The same statutory version and jurisdiction apply.
- The procedural stage and burden of proof are comparable.
- The material documentary record is substantially similar.
Weaker / distinguishable when
- A later higher-court ruling changes the position.
- The statutory provision or relevant period differs.
- The evidence or procedural chronology is materially different.
- A defect decisive here was cured in the user's case.
Questions this judgment answers
What was the main dispute in PCIT Chandigarh v. ABC Papers Limited?
PCIT Chandigarh Vs ABC Papers Limited (Supreme Court) Date-18th August 2022 Sub-The Hon’ble Supreme court in this case was called upon to decide which High Court would have the jurisdiction to entertain an appeal against a decision of a Bench of the ITAT exercising jurisdiction over more than one state, particularly when case(s) of same assessment year are transferred under Section 127 of the Act. Should it be the High Court of the State in which the ITAT is physically located or the High Court of the State in which the Assessee is residing and/or doing its business or the High Court where the Assessing Officer…
Which facts matter most?
PR. COMMISSIONER OF INCOME TAX – I, CHANDIGARH ...APPELLANT
What did the Supreme Court decide?
said Civil Appeal is dismissed by upholding the order dated 07.02.2019 passed
What legal principle can be taken from the judgment?
The packaged judgment addresses PCIT Chandigarh Vs ABC Papers Limited (Supreme Court) Date-18th August 2022 Sub-The Hon’ble Supreme court in this case was called upon to decide which High Court would have the jurisdiction to entertain an appeal against a decision of a Bench of the ITAT exercising jurisdiction over more than one state, particularly when case(s) of same assessment year are transferred under Section 127 of the Act. Should it be the High Court of the State in which the ITAT is physically located or the High Court of the State in which the Assessee is residing and/or doing its business or the High Court where the Assessing Officer…. The precise proposition must be read with the Court/Tribunal's reasoning and operative directions. Reliance depends on matching the statutory version, jurisdiction, procedural stage and material evidence recorded in the judgment.
Which provisions should be checked?
127 of the Income-tax Act, 1961
When is the case most useful?
When the user's facts raise the same issue - PCIT Chandigarh Vs ABC Papers Limited (Supreme Court) Date-18th August 2022 Sub-The Hon’ble Supreme court in this case was called upon to decide which High Court would have the jurisdiction to entertain an appeal against a decision of a Bench of the ITAT exercising jurisdiction over more than one state, particularly when case(s) of same assessment year are transferred under Section 127 of the Act. Should it be the High Court of the State in which the ITAT is physically located or the High Court of the State in which the Assessee is residing and/or doing its business or the High Court where the Assessing Officer… - at a comparable procedural stage and under the same statutory version.
What could distinguish the case?
Different evidence, jurisdiction, statutory period, procedural chronology, or later controlling authority can materially change the result.
Can it be cited without another current-law check?
No. Read the packaged judgment and verify current appellate/review/SLP history, statutory amendments and jurisdiction before citation or advice.
Section / provision impact
- 127 of the Income-tax Act - apply the exact version considered in the judgment.
- 1961 - apply the exact version considered in the judgment.
Case network
Similar issue / useful comparison
- Agreeko Energy Rental Vs DCIT - ITAT Pune
- BASHIR AHMAD SOFI V ITO WARD 1 - ITAT Amritsar
- Chennai Port Authority v. NFAC - Madras High Court
Different outcome / possible distinction
- PCIT v. Khyati Realtors Private Limited - Quashed / set aside
- S R Cold Storage v. UOI and Others (Allahabad High Court) - Quashed / set aside
Related Finin2min resources
Full judgment and source control
Read / download packaged judgment record
Source class: Sanitized official primary judgment copy · Repository status: Published
Finin2min Judgment Intelligence is provided for general informational and educational purposes only. It is not legal, tax, accounting, investment or other professional advice and is not a substitute for advice on the user's specific facts. The Finin2min summary, Q&A, reliance profile, fact-match indicators, comparisons and practical takeaways are editorial analysis and are not part of the Court/Tribunal judgment. Before citing, filing, advising or acting on a case, read the complete official judgment/order, verify the cause title, case number, coram, date, applicable statutory text and jurisdiction, and check subsequent appellate history, review/SLP status and later amendments. A similar fact pattern does not guarantee the same outcome. No advocate-client, CA-client or other professional relationship is created by use of this page.
Sections and statute
The numbered references below belong to the statutes and versions identified in this judgment. They are citation labels, not a crosswalk to same-number sections of the Income-tax Act, 2025.
Section 127