Statutory remedy and disputed facts bar writ challenge to tax notices where the Income-tax Act provides complete redress.

Writ petitions challenging notices were held not maintainable where the Income-tax Act provided an ordinary statutory remedy and the dispute turned on contested facts. The Court noted that the assessees could raise both factual and legal objections before the concerned Income-tax Officers, and that the Act operates as a complete code for such grievances. Because the controversy involved disputed questions of fact and no special circumstances justified bypassing the normal remedy, writ jurisdiction was declined and the petitioners were directed to pursue the statutory process.

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Issues: Whether the writ petitions challenging notices under section 186 of the Income-tax Act, 1961 were maintainable when the petitioners had an ordinary statutory remedy before the Income-tax Officers and the controversy involved disputed questions of fact.

Analysis: The petitions assailed show-cause notices proposing cancellation of registration on the ground that the assessees had allegedly taken partners without approval under the Arms Act. The Court held that the Income-tax Act is a complete code providing remedies to the assessees, and that the petitioners could raise all factual and legal objections before the concerned Income-tax Officers. Since the controversy raised disputed questions of fact, writ proceedings were not the appropriate forum. The Court also found no special circumstances warranting bypass of the ordinary remedy under law.

Conclusion: The writ jurisdiction was declined and the petitioners were relegated to pursue the statutory remedy before the concerned Income-tax Officers.

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