Court dismisses petitions challenging Income-tax Act notices; emphasizes exhausting alternative remedies before approaching High Court.

The High Court dismissed the writ petitions challenging Income-tax Act notices for various assessment years. The petitioner, Karnataka Industrial Areas Development Board, sought exemption under section 10(20A) of the Act, claiming to fall under statutory bodies eligible for exemption. The court emphasized exhausting alternative remedies before invoking High Court jurisdiction under article 226, stating it should be for specific circumstances like fundamental rights infringement or jurisdictional errors. As the petitioner failed to establish interference necessity with the assessment proceedings, the writ petitions were dismissed, underscoring the need to exhaust alternative remedies before seeking relief through the High Court.

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Issues:
Challenge to notices issued under Income-tax Act for assessment years 1982-83, 1983-84, 1984-85, and 1985-86.
Claim of exemption under section 10(20A) of the Income-tax Act by the petitioner.
Jurisdiction of the High Court to entertain writ petitions in such matters.

Analysis:
The Karnataka Industrial Areas Development Board (the petitioner) challenged notices issued under the Income-tax Act for various assessment years. The petitioner claimed exemption under section 10(20A) of the Act, citing the purpose of its constitution under the Karnataka Act No. 18 of 1966. The main contention was that the Board falls under statutory bodies described in section 10(20A) and is eligible for exemption. The petitioner argued that the assessing authority should grant the exemption based on the Act's provisions and the plea put forward by the Board. The petitioner approached the High Court under article 226 of the Constitution seeking relief, as the Commissioner expressed inability to grant exemption in correspondence. The Revenue raised a preliminary objection, stating that the assessing authority should decide the exemption claim on its merits. The petitioner relied on a judgment of the Gujarat High Court to support its claim for exemption under section 10(20A).

The High Court considered the legal position that the Income-tax Act provides a complete machinery for tax assessment and relief, emphasizing the need to exhaust alternative remedies before invoking the High Court's jurisdiction under article 226. The court referred to previous decisions reiterating that the High Court's jurisdiction should be invoked only in specific circumstances, such as infringement of fundamental rights or jurisdictional errors by tax authorities. The court noted that the petitioner should present all contentions before the Income-tax Officer and challenge any adverse orders through the appeal process provided by the Act. Ultimately, the court held that the petitioner failed to establish a case for interfering with the assessment proceedings under the jurisdiction of the Income-tax Officer. As a result, the writ petitions were dismissed, emphasizing the need to exhaust alternative remedies before seeking relief through the High Court.

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