Jurisdiction of TRO [Section 223]
- The certificate may be executed by TRO:
o where the assessee carries on a business/profession, or
o where the assessee resides/has property.
- If the assessee has property in multiple jurisdictions and recovery is difficult or needs to be expedited, a certificate (or part thereof) can be forwarded to another TRO who can recover as if he had drawn the certificate himself.