Civil court jurisdiction is barred from restraining income-tax assessments under Section 293.

Section 293 of the Income-tax Act bars a civil suit that, in substance, seeks to prevent or modify assessment proceedings, and also protects acts done or intended in good faith under the Act. A prayer framed as an injunction against future assessment action cannot bypass this statutory bar. Objections on taxability, pending litigation affecting compensation, or alleged non-compliance with directions in appellate proceedings must be pursued before the income-tax authorities and through the statutory appellate mechanism, not in civil court. The civil court therefore lacks jurisdiction to entertain such a suit or grant an injunction against the Income-tax Officer.

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Issues: Whether the civil court had jurisdiction to restrain the Income-tax Officer from proceeding with assessments in view of the statutory bar under section 293 of the Income-tax Act.

Analysis: Section 293 bars any suit in a civil court to set aside or modify an assessment order and also bars proceedings against the Government or its officers for acts done or intended to be done in good faith under the Act. The challenge before the civil court, though framed as a restraint against future assessment action, in substance sought to prevent the officer from proceeding under the Act. The assessee's objections to the merits of taxability, the effect of pending civil litigation concerning acquisition and compensation, and the alleged breach of directions issued in appellate proceedings under the Act were matters to be raised before the income-tax authorities and in the statutory appellate framework, not before the civil court.

Conclusion: The civil court had no jurisdiction to entertain the suit or grant an injunction against the Income-tax Officer.

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