BHAVENDRA HASMUKHLAL PATADIA vs The UNION OF INDIA

Whether the High Court of Gujarat has territorial jurisdiction to entertain a writ petition challenging a reassessment notice under Section 148 of the Income Tax Act, 1961, issued by an Assessing Officer in Cuttack, Orissa, when part of the cause of action (service of a notice under Section 143(2) at Ahmedabad) is claimed to have arisen within Gujarat --- Held No, as the integral facts constituting the cause of action for challenging the reassessment notice (issuance of notice under Section 148, filing of return, and passing of assessment order) all occurred in Orissa, and the service of a subsequent notice under Section 143(2) at Ahmedabad is not an integral part of the cause of action for the writ petition.