Writ interference with income-tax penalty notice refused where the notice was issued to the partnership firm, not the individual partner.

A writ challenge to a notice under section 221(1) of the Income-tax Act was rejected because the notice was addressed to the partnership firm, not to an individual partner. The High Court found no factual basis to treat the notice as one issued against the partner personally, and therefore saw no reason to exercise writ jurisdiction under Article 226. The impugned notice was left undisturbed and the petition was dismissed.

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Issues: Whether the Court should interfere under Article 226 with the notice issued under section 221(1) of the Income-tax Act, 1961, on the ground that it was allegedly being enforced against an individual rather than the firm.

Analysis: The notice was addressed to the partnership firm, and the Court found no basis to treat it as one directed against the individual partner in the manner alleged. In view of that position, the grievance did not warrant adjudication on merits in writ jurisdiction.

Conclusion: The Court declined to interfere with the impugned notice and dismissed the writ petition.

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