Validity challenge to presumptive tax collection provisions failed, but pending representation for certificate was directed to be decided in law.

The constitutional challenge to sections 44AC and 206C of the Income-tax Act, 1961 was held to be unavailable because the Supreme Court had already upheld those provisions and rejected the Article 14 objection to the presumptive collection mechanism. The Court therefore declined to entertain the validity challenge. On the separate request concerning certificates under the proviso to section 206C, it granted limited relief by directing the competent authority to decide the pending representation in accordance with law within one month.

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Issues: (i) Whether the challenge to the validity of sections 44AC and 206C of the Income-tax Act, 1961 could survive; (ii) Whether the petitioners were entitled to a direction for decision on their representation seeking certificates under the proviso to section 206C.

Issue (i): Whether the challenge to the validity of sections 44AC and 206C of the Income-tax Act, 1961 could survive.

Analysis: The constitutional challenge stood covered by the Supreme Court's ruling upholding the validity of the provisions and rejecting the contention that the presumptive collection mechanism offended Article 14 of the Constitution of India.

Conclusion: The challenge to the validity of sections 44AC and 206C was not entertained and did not survive.

Issue (ii): Whether the petitioners were entitled to a direction for decision on their representation seeking certificates under the proviso to section 206C.

Analysis: The petitioners' request was confined to a direction that the representation be decided in accordance with law. The Court accepted that limited relief and directed the competent authority to decide the representation within the stipulated time.

Conclusion: A direction was issued to decide the representation within one month in accordance with law.

Final Conclusion: The writ petition succeeded only to the limited extent of securing disposal of the pending representation, while the substantive constitutional challenge failed.

Ratio Decidendi: A writ court will not entertain a constitutional challenge to statutory provisions that has already been authoritatively rejected by the Supreme Court, but may grant limited relief directing consideration of a pending representation in accordance with law.

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